Double taxation relief through foreign tax credit limits credits to domestic tax and treaty limitations. Article 23 mandates mutual allowance of a credit for tax paid in the other Contracting State against domestic tax on income derived from that State; income taxable under the Convention is deemed to arise from the source State. The definition of foreign tax credit includes amounts that would have been payable but for specified deductions, exemptions or reductions, and the credit is limited to the lesser of the domestic tax otherwise payable and any treaty-specific limitation.