Article 23 - Elimination of double taxation

Double taxation relief: tax paid abroad may be credited against domestic tax, subject to attributable tax limits and incentives.

Article 23 prescribes bilateral relief by allowing residents to deduct from domestic tax an amount equal to income-tax paid in the other Contracting State, whether paid directly or by deduction at source, limited to the portion of domestic tax attributable to the income taxable abroad; taxes reduced by domestic development incentives are treated as deemed payable for credit purposes, and income exempt under the Convention may be taken into account in calculating applicable tax rates.