Double taxation relief: bilateral tax-credit rules allow credit for foreign tax plus special dividend and incentive rules. The Convention provides bilateral credit relief: each Contracting State taxes residents under domestic law but allows a credit for tax paid in the other State on the same income, capped by the tax attributable to that income. Special provisions treat dividends where the shareholder owns at least 10 per cent of the paying company, and certain domestic exemptions or incentive-based reductions are deemed ''tax payable'' for credit purposes. Where income is exempt under the Convention, the residence State may calculate tax on remaining income using the rate that would have applied had the exempt income not been exempted.