Doppelbesteuerung

Chapter V. METHODS FOR THE ELIMINATION OF DOUBLE TAXATION

Art. 23A Exemption method

(1) Where a resident of a Contracting State derives income or owns capital which may be taxed in the other Contracting State, in accordance with the provisions of this Convention (except to the extent that these provisions allow taxation by that other State solely because the income is also income derived by a resident of that State or because the capital is also capital owned by a resident of that State), the first-mentioned State shall, subject to the provisions of paragraphs 2 and 3, exempt such income or capital from tax.

(2) Where a resident of a Contracting State derives items of income which, in accordance with the provisions of Articles 10, 11, 12, and 12A may be taxed in the other Contracting State, the first-mentioned State shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in that other State. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income which may be taxed in that other State.

(3) Where in accordance with any provision of this Conve...