Avoidance of double taxation

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....e express provision to the contrary is made in this Agreement. 2. Where a resident of India derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Cyprus, India shall allow as a deduction from the tax on the income of that resident an amount equal to the income-tax paid in Cyprus whether directly or by deduction; and as a deduction from the ta....

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....n shall not, however, exceed that part of the tax, as computed before the deduction is given, which is appropriate to such income derived in India. 4. The tax payable in a Contracting State mentioned in paragraph 2 and paragraph 3 of this Article shall be deemed to include the tax which would have been payable but for the tax incentives granted under the laws of the Contracting States and which....