Avoidance of double taxation: residence state allows deduction for foreign taxes paid, limited to attributable income.

Avoidance of double taxation is implemented by a reciprocal relief mechanism under which the residence State permits a deduction from tax on income and capital equal to the tax paid in the other State, limited to the part attributable to income or capital taxable in that other State. The method applies symmetrically, and exempt income may be considered when calculating the tax rate; taxes deemed payable include amounts notwithstanding domestic tax incentives aimed at economic development.

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