Article 24 - Elimination of double taxation

Elimination of double taxation: tax credit relief limited to residence tax attributable to foreign-source income, with surtax ordering.

Relief from double taxation is provided by a Tax Credit allowing residents taxed in both States to credit source-State tax against residence-State tax, limited to the residence-State tax attributable to that income; for resident companies subject to surtax, the credit is applied first against income tax and then, if any balance remains, against surtax. The Convention also deems source- and residence-State tax payable to include taxes reduced or exempted under the Convention or special incentive measures designed to promote economic development, so that credits reflect hypothetical tax otherwise payable.