Article 24 - Elimination of Double Taxation

Elimination of double taxation: mutual credit relief limits foreign tax credit to tax attributable to taxed income, reciprocal.

Article 24 implements reciprocal foreign tax credit relief: each Contracting State allows a deduction for tax paid in the other State, limited to the portion of domestic tax attributable to the income or capital taxable abroad. The payable tax for credit purposes includes taxes that would have been payable absent domestic tax incentives. When income or capital is exempt under the Convention, the resident State may still consider the exempted amount in calculating tax on the resident's remaining taxable base.