ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows:
(1) In the case of Austria:
a) Where a resident of Austria derives income which, in accordance with the provisions of this Convention, may be taxed in the United Kingdom, Austria shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax on income or capital gains paid in the United Kingdom; Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital gains which may be taxed in the United Kingdom.
b) Where in accordance with any provision of the Convention income derived by a resident of Austria is exempt from tax in that State, Austria may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
(2) Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom or, as the case may be, regarding the exemption from United Kingdom tax of a dividend arising in a territory outside the United Kingdom or of the profits of a permanent establishment situated in a territory outside the United Kingdom (which shall not affect the general principle hereof):
a) Austrian tax payable under the laws of Austria and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any United Kingdom tax computed by reference to the same profits, income or chargeable gains by reference to which the Austrian tax is computed;
b) a dividend which is paid by a company which is a resident of Austria to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met;
c) the profits of a permanent establishment in Austria of a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met;
d) in the case of a dividend not exempted from tax under subparagraph b) above which is paid by a company which ...
ELIMINATION OF DOUBLE TAXATION. 1. The laws of each Contracting State shall continue to govern the taxation of income in that State except where express provision to the contrary is made in the present Agreement. Where income is subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following paragraphs of this Article.
ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows:
ELIMINATION OF DOUBLE TAXATION. 1. It is agreed that double taxation shall be avoided in accordance with the following paragraphs of this Article.
ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, Brunei Darussalam tax payable under the laws of Brunei Darussalam and in accordance with this Agreement by a resident of Malaysia in respect of income derived from Brunei Darussalam shall be allowed as a credit against Malaysian tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Brunei Darussalam to a company which is a resident of Malaysia and which owns not less than 25 per cent of the voting shares of the company paying the dividend, the credit shall take into account Brunei Darussalam tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income.
2. For the purposes of paragraph 1, the term “Brunei Darussalam tax payable” shall be deemed to include the amount of tax which would have been paid if the tax had not been exempted or reduced in accordance with the special incentive laws designed to promote economic development in Brunei Darussalam, effective on the date of signature of this Agreement, or which may be introduced hereafter in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character.
3. Subject to the laws of Brunei Darussalam regarding the allowance as a credit against Brunei Darussalam tax of tax payable in any country other than Brunei Darussalam, Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Brunei Darussalam in respect of income derived from Malaysia shall be allowed as a credit against Brunei Darussalam tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Malaysia to a company which is resident of Brunei Darussalam and which owns not less than 25 per cent of the voting shares of the company paying the dividend, the credit shall take into account Malaysian tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Brunei Darussalam tax, as computed before the credit is given, which is appropriate to such item of income.
4. For the purposes of paragraph ...
ELIMINATION OF DOUBLE TAXATION. 1. Subject to any provisions of the laws of New Zealand which may from time to time be in force which relate to the allowance of a credit against New Zealand tax of tax paid in a country outside New Zealand (which shall not affect the general principle of this Article), Singapore tax paid under the laws of Singapore and consistent with this Agreement, whether directly or by deduction, in respect of income derived by a resident of New Zealand from sources in Singapore (excluding, in the case of a dividend, tax paid in respect of the profits out of which the dividend is paid) shall be allowed as a credit against New Zealand tax payable in respect of that income.
2. Subject to any provisions of the laws of Singapore which may from time to time be in force and which relate to the allowance of a credit against Singapore tax of tax paid in a country outside Singapore (which shall not affect the general principles hereof), New Zealand tax paid under the law of New Zealand and in accordance with this Agreement, whether directly or by deduction, in respect of income derived by a Singapore resident from sources in New Zealand (excluding, in the case of a dividend, tax paid in respect of profits out of which the dividend is paid) shall be allowed as a credit against Singapore tax payable in respect of that income. However, where such income is a dividend paid by a company which is a New Zealand resident to a company which is a Singapore resident and which beneficially owns at least 10% of the paid-up share capital in the first-mentioned company the credit shall take into account (in addition to any New Zealand tax on dividends) the New Zealand tax paid by the first-mentioned company in respect of its profits.
3. For the purposes of paragraph 1 of this Article, a New Zealand resident deriving income from sources in Singapore consisting of −
(a) profits, being profits in respect of which an exemption from Singapore tax has been granted under the provisions of the Economic Expansion Incentives (Relief from Income Tax) Act, (Chapter 86) of Singapore; or
(b) interest or royalties, being interest or royalties in respect of which an exemption from or reduction of Singapore tax has been granted under the provisions of the said Economic Expansion Incentives (Relief from Income Tax) Act, (Chapter 86) − shall be deemed to have paid Singapore tax in an amount or, as the case may be, the Singapore tax paid shall be deemed to have been increased by an amount equal to the amount by...
ELIMINATION OF DOUBLE TAXATION. 1. In Luxembourg double taxation shall be eliminated as follows:
(a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Singapore, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (e), exempt such income or capital from tax.
(b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 and 20 may be taxed in Singapore, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Singapore. 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 derived from Singapore.
(c) For the purposes of sub-paragraph (b) of paragraph 1 the term "tax paid in Singapore" shall be deemed to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be:
(i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10;
(ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and
(iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12.
(d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
(e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted fr...
ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan regarding the allowance as a credit against Kazakhstan tax of tax payable in any country other than Kazakhstan, the Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia shall be allowed as a credit against Kazakhstan tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income.
2. For the purposes of paragraph 1, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and the special incentives under the Malaysian laws for the promotion of economic development of Malaysia which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character.
3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income.
4. For the purposes of paragraph 3, the term "Kazakhstan tax payable" shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which ...
ELIMINATION OF DOUBLE TAXATION. 1. In the case of Lithuania, double taxation shall be avoided as follows: where a resident of Lithuania derives income which, in accordance with this Convention, may be taxed in Belgium, unless a more favorable treatment is provided in its domestic law, Lithuania shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Belgium. Such deduction shall not, however, exceed that part of the income tax in Lithuania, as computed before the deduction is given, which is attributable to the income which may be taxed in Belgium.
2. In the case of Belgium, double taxation shall be avoided as follows:
a) Where a resident of Belgium derives income which is taxed in Lithuania in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article 12, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted.
b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraph 2 or 7 of Article 11, or royalties taxable in accordance with paragraph 2 or 6 of Article 12, the Lithuanian tax levied on that income shall be allowed as a credit against Belgian tax relating to such income.
c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Lithuania, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law.
d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Lithuania, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax i...
ELIMINATION OF DOUBLE TAXATION. Where a resident of a Contracting State derives income which, in accordance with the provisions of this Agreement, 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 income tax paid in that other State. Such deduction shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable to the income which may be taxed in that other State.
