Common use of ELIMINATION OF DOUBLE TAXATION Clause in Contracts

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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of AustriaKazakhstan, double taxation shall be avoided as follows: a) Where a resident of Austria Kazakhstan derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the United KingdomAustria, Austria Kazakhstan shall allow allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Austria; (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Austria. The amount of the tax to be deducted pursuant to the above provision shall not exceed the lesser of the tax which would have been charged on the same income in Kazakhstan under the rates applicable therein. b) Where a resident of Kazakhstan derives income or owns capital, which in accordance with the provisions of this Convention shall be taxable only in Austria, Kazakhstan may include this income or capital gains in the tax base but only for purposes of determining the rate of tax on such other income or capital as is taxable in Kazakhstan. (2) In the case of Austria, double taxation shall be avoided as follows: a) Where a resident of Austria derives income or owns capital which, in accordance with the provisions of this Convention may be taxed in Kazakhstan, Austria shall, subject to the provisions of sub-paragraphs b), c) and d), exempt such income or capital from tax. b) Where a resident of Austria derives items of income which, in accordance with the provisions of Articles 10, 11 and 12 may be taxed in Kazakhstan, Austria shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the United Kingdom; Kazakhstan. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, given which is attributableattributable to such items of income derived from Kazakhstan. c) Dividends covered by paragraph 2 sub-paragraph a) of Article 10 and paid by a company which is a resident of Kazakhstan to a company which is a resident of Austria shall, as the case may be, subject to the income or relevant provisions of the capital gains which may domestic law of Austria but irrespective of any deviating minimum holding requirements of that law, be taxed exempt from tax in the United KingdomAustria. bd) Where in accordance with any provision of the this Convention income derived or capital owned by a resident of Austria is exempt from tax in that StateAustria, Austria may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted incomeincome or capital. (2e) 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 Income derived 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 considered by a company which is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power be taxable under this Convention in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which Kazakhstan may nevertheless be taxed in Austria if, after the other Contracting State in accordance with conduct of a mutual agreement procedure, Kazakhstan does not tax that income by virtue of this Convention shall be deemed to arise from sources in that other StateConvention.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of AustriaAlbania: a) Where a resident of Austria Albania derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the United KingdomAustria, Austria Albania shall allow allow: (i) as a deduction from the Albanian tax on the income of that resident, an amount equal to the income tax paid in Austria; (ii) as a deduction from Albanian tax on income or the capital gains of that resident, an amount equal to the capital tax paid in the United Kingdom; Austria. Such deduction in either case shall not, however, exceed that part of the Albanian tax on income taxor on capital, 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 KingdomAustria. b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Albania is exempt from tax in Albania, Albania 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. (2) In Austria: a) Where a resident of Austria derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Albania, Austria shall, subject to the provisions of subparagraphs b) and c), exempt such income or capital from tax. b) Where a resident of Austria derives items of income which, in accordance with the provisions of Articles 10, 11 and 12, may be taxed in Albania, Austria shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Albania. 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 Albania. c) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria is exempt from tax in that StateAustria, Austria may nevertheless, in calculating the amount of tax on the remaining income or capital 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;capital. d) in the case The provisions of a dividend not exempted from tax under subparagraph b) above which is paid by a company which is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, not apply to income and gains derived or capital owned by a resident of a Contracting State which may be taxed in Austria where Albania applies the other Contracting State in accordance with provisions of this Convention shall be deemed to arise exempt such income or capital from sources in that other Statetax or applies the provisions of paragraph 2 of Articles 10, 11 or 12 to such income.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of Austriaa resident of Austria double taxation shall be avoided as follows: a) Where a resident of Austria derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Latvia, Austria shall, subject to the United Kingdomprovisions of subparagraphs b) to e), exempt such income or capital from tax. b) Where a resident of Austria derives items of income which, in accordance with the provisions of Articles 10, 11 and 12 may be taxed in Latvia, Austria shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Latvia. 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 Latvia. c) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria is exempt from tax in Austria, Austria 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. d) Income derived by a resident of Austria which is considered by Austria to be taxable under this Convention in Latvia may nevertheless be taxed in Austria if, after the conduct of a mutual agreement procedure, Latvia exempts that income from tax by virtue of this Convention. e) Where a company that is a resident of Austria derives dividends from a company that is a resident of Latvia in which it owns at least 10% of the share capital Austria shall exempt such dividends under the conditions set out for the international holding privilege in the generally applicable provisions of the law of Austria. (2) In the case of a resident of Latvia double taxation shall be avoided as follows: a) Where a resident of Latvia derives income or owns capital which, in accordance with this Convention, may be taxed in Austria, unless a more favourable treatment is provided in its domestic law, Latvia shall allow: i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Austria; ii) as a deduction from the tax on income or the capital gains of that resident, an amount equal to the capital tax paid thereon in the United Kingdom; Austria. Such deduction in either case shall not, however, exceed that part of the income tax, tax or capital tax in Latvia 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 KingdomAustria. b) Where in accordance with any provision For the purposes of the Convention income derived by subparagraph a), where a company that is 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 Latvia receives 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 that is a resident of Austria to a company in 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly it owns at least 10 per cent of its shares having full voting rights, the voting power tax paid in Austria shall include not only the company paying tax paid on the dividend, but also the credit mentioned in subparagraph a) above shall also take into account tax paid on the Austrian tax payable by underlying profits of the company in respect of its profits out of which such the dividend is was paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of a resident of Austria, double taxation shall be avoided as follows: a) Where a resident of Austria derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Lithuania, Austria shall, subject to the United Kingdomprovisions of subparagraphs b) to e), exempt such income or capital from tax; b) Where a resident of Austria derives items of income which, in accordance with the provisions of Articles 10, 11 and 12 may be taxed in Lithuania, Austria shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Lithuania. 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 Lithuania; c) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria is exempt from tax in Austria, Austria 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; d) Income derived by a resident of Austria which is considered by Austria to be taxable under this Convention in Lithuania may nevertheless be taxed in Austria if, after the conduct of a mutual agreement procedure, Lithuania exempts that income from tax by virtue of this Convention; e) Where a company that is a resident of Austria derives dividends from a company that is a resident of Lithuania in which it owns at least 10 per cent of the share capital Austria shall exempt such dividends under the conditions set out for the international holding privilege in the generally applicable provisions of the law of Austria. (2) In the case of a resident of Lithuania, double taxation shall be avoided as follows: a) Where a resident of Lithuania derives income or owns capital which, in accordance with this Convention, may be taxed in Austria, unless a more favourable treatment is provided in its domestic law, Lithuania shall allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Austria; (ii) as a deduction from the tax on income or the capital gains of that resident, an amount equal to the capital tax paid thereon in the United Kingdom; Austria. Such deduction in either case shall not, however, exceed that part of the income taxtax or capital tax in Lithuania, 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 KingdomAustria. b) Where in accordance with any provision For the purposes of the Convention income derived by subparagraph a), where a company that is 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 Lithuania receives 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 that is a resident of Austria to a company in 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly it owns at least 10 per cent of its shares having full voting rights, the voting power tax paid in Austria shall include not only the company paying tax paid on the dividend, but also the credit mentioned in subparagraph a) above shall also take into account tax paid on the Austrian tax payable by underlying profits of the company in respect of its profits out of which such the dividend is was paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of a resident of Austria, double taxation shall be eliminated as follows: a) Where a resident of Austria derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the United KingdomCzech Republic, Austria shall, subject to the provisions of sub-paragraph b) and paragraph 3, exempt such income or capital from tax. b) Where a resident of Austria derives items of income which, in accordance with the provisions of Articles 10 and 12, may be taxed in the Czech Republic, Austria shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the tax on income or capital gains paid in the United Kingdom; Czech Republic. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributableattributable to such items of income derived from the Czech Republic. c) The provisions of sub-paragraph a) shall not apply to income derived or capital owned by a resident of Austria where the Czech Republic applies the provisions of this Convention to exempt such income or capital from tax or applies the provisions of paragraph 2 of Article 10 or 12 to such income. (2) In the case of a resident of the Czech Republic, double taxation shall be eliminated as follows: The Czech Republic, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income or of capital which according to the provisions of this Convention may also be taxed in Austria, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Austria. Such deduction shall not, however, exceed that part of the Czech tax, as computed before the case may bededuction is given, which is appropriate to the income or capital which, in accordance with the capital gains which provisions of this Convention, may be taxed in the United KingdomAustria. b(3) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria a Contracting State is exempt from tax in that State, Austria such State may nevertheless, in calculating the amount of tax on the remaining income or capital 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paidcapital. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

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 ConventionAgreement, may be taxed in Turkey, Austria shall, subject to the United Kingdomprovisions of subparagraphs b) to e), exempt such income from tax. b) Where a resident of Austria derives items of income which, in accordance with the provisions of paragraph 2 of Article 10, paragraphs 2 and 4 of Article 11, paragraph 2 of Article 12, second sentence of paragraph 4 of Article 13 and paragraph 1 of Article 21, may be taxed in Turkey, Austria shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the tax on income or capital gains paid in the United Kingdom; Turkey. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributableattributable to such items of income derived from Turkey. c) Dividends in the sense of subparagraph b) (i) of paragraph 2 of Article 10 paid by a company which is a resident of Turkey to a company which is a resident of Austria shall be exempt from tax in Austria, subject to the relevant provisions of the domestic law of Austria, as it may change from time to time without affecting the case may begeneral character of those provisions, to the income or the capital gains which may be taxed in the United Kingdombut irrespective of any deviating minimum holding requirements provided for by that law. bd) Where in accordance with any provision of the Convention Agreement income derived by a resident of Austria is exempt from tax in that StateAustria, Austria may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. (2e) Subject Where a resident of Austria derives interest or royalties from Turkey and such interest or royalties are taxed in Turkey at a rate of tax which is, in the case of interest less than the rates provided for in subparagraphs a) to c) of paragraph 2 of Article 11 and in the provisions case of the law of the United Kingdom regarding the allowance royalties less than 10 per cent then there shall be allowed as a credit against United Kingdom deduction from the Austrian tax of tax payable in a territory outside on the United Kingdom orinterest or royalties, 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 Conventionan amount equal to, 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 interest 5 per cent, 10 per cent or 15 per cent, as 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 profitscase may be, 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least royalties 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect gross amount of its profits out of which such dividend is paidinterest or royalties. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as followsIn Argentina: (1) In the case of Austria: a) . Where a resident of Austria Argentina derives income which, or owns capital which may be taxed in Austria in accordance with the provisions of this ConventionConvention (except to the extent that these provisions allow taxation by Austria solely because the income is also income derived by a resident of Austria or because the capital is also capital owned by a resident of Austria), may be taxed in the United Kingdom, Austria Argentina shall allow allow: a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Austria; b) as a deduction from the tax on income or the capital gains of that resident, an amount equal to the capital tax paid in the United Kingdom; Austria. Such deduction in either case shall not, however, exceed that part of the income tax or capital 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 Austria. Where in accordance with any provision of this Convention income derived or capital owned by a resident of Argentina is exempt from tax therein, Argentina may nevertheless, in calculating the United Kingdomamount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. 2. In Austria: a) Where a resident of Austria derives income or owns capital which may be taxed in Argentina in accordance with the provisions of this Convention (except to the extent that these provisions allow taxation by Argentina solely because the income is also income derived by a resident of Argentina or because the capital is also capital owned by a resident of Argentina), Austria shall, subject to the provisions of subparagraphs b) to d), exempt such income or capital from tax. b) Where a resident of Austria derives items of income which may be taxed in Argentina in accordance with the provisions of Articles 10, 11, 12, paragraphs 4 and 5 of Article 13 and paragraph 3 of Article 21 (except to the extent that these provisions allow taxation by Argentina solely because the income is also income derived by a resident of Argentina), Austria shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Argentina. 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 Argentina. c) Dividends in the sense of subparagraph a) of paragraph 2 of Article 10 paid by a company which is a resident of Argentina to a company which is a resident of Austria shall be exempt from tax in Austria, subject to the relevant provisions of the domestic law of Austria but irrespective of any deviating minimum holding requirements provided for by that law. d) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria is exempt from tax in that StateAustria, Austria may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted incomeincome or capital. (2e) Subject to the 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, not apply to income and gains derived or capital owned by a resident of a Contracting State which may be taxed in Austria where Argentina applies the other Contracting State in accordance with provisions of this Convention shall be deemed to arise exempt such income or capital from sources in that other Statetax or applies the provisions of paragraph 2 of Article 10, 11 or 12 to such income.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of AustriaAustria double taxation shall be eliminated as follows: a) Where a resident of Austria derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the United KingdomBarbados, Austria shall allow allow: i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Barbados; ii) as a deduction from the tax on income or the capital gains of that resident, an amount equal to the capital tax paid in the United Kingdom; Barbados. Such deduction in either case shall not, however, exceed that part of the income tax or capital 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 KingdomBarbados. b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria is exempt from tax in that StateAustria, Austria may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted incomeincome or capital. (2) Subject In the case of Barbados, subject to the provisions of the law laws of the United Kingdom Barbados regarding the allowance as a credit against United Kingdom Barbados tax of tax payable in a territory outside the United Kingdom or, Barbados double taxation shall be eliminated 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):follows: a) Austrian tax payable under the laws of Austria and in accordance with this the Convention, whether directly or by deduction, on profits, profits or income or chargeable gains from sources within Austria (excluding 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 Barbados tax computed by reference to the same profits, profits or income or chargeable gains by reference to in respect of which the Austrian tax is computed; b) in the case of a dividend which is paid by a company which that is a resident of Austria to a company which that 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 is a resident of Austria to a company which is a resident of the United Kingdom Barbados and which controls holds directly or indirectly at least 10 per cent of the voting power in capital of the company paying the dividend, the credit mentioned referred to in subparagraph sub- paragraph (a) above shall also take into account the Austrian tax payable by the company paying the dividend in respect of its the profits out of which such dividend is paid.; and (3c) For the purposes credit, however, shall in no case exceed the part of paragraphs 1 and 2the tax, profitsas computed before the deduction is given, which is appropriate to the income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other StateAustria.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case of Austria: a) Where Lesotho, subject to the provisions of the law of Lesotho, from time to time in force, which relates to the allowance of credit against Lesotho tax of tax paid in a resident country outside Lesotho (which shall not affect the general principle of Austria derives income whichthis Article), United Kingdom tax paid under the law of the United Kingdom and in accordance with the provisions this Agreement, whether directly or by deduction, in respect 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 person who is a resident of Austria is exempt Lesotho from sources in the United Kingdom shall be allowed as a credit against Lesotho tax payable in respect of 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 Lesotho tax payable under the laws of Austria Lesotho and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Lesotho (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 Lesotho tax is computed; b) a dividend which is paid by a company which is a resident of Austria Lesotho to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Lesotho 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 sub-paragraph b) above which is paid by a company which is a resident of Austria Lesotho to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Lesotho tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double (1) In Armenia double taxation shall be eliminated as follows: (1) In the case of Austria: a) : Where a resident of Austria Armenia derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the United KingdomAustria, Austria Armenia shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Austria; and as a deduction from the tax on the capital of that resident, an amount equal to the capital tax on income or capital gains paid in the United Kingdom; Austria. Such deduction in either case shall not, however, exceed that part of the income tax or capital 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 Austria. (2) In Austria double taxation shall be eliminated as follows: a) Where a resident of Austria derives income or owns capital which, in accordance with the United Kingdomprovisions of this Convention, may be taxed in Armenia, Austria shall, subject to the provisions of sub-paragraphs b) and c) and paragraph 3, exempt such income or capital from tax. b) Where a resident of Austria derives items of income which, in accordance with the provisions of paragraphs 2 of Articles 10, 11 and 12, paragraphs 4 of Article 13 and paragraph 3 of Article 21 may be taxed in Armenia, Austria shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Armenia. 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 Armenia. c) Dividends in the sense of sub-paragraph a) of paragraph 2 of Article 10 paid by a company which is a resident of Armenia to a company which is a resident of Austria shall be exempt from tax in Austria, subject to the relevant provisions of the domestic law of Austria, however, notwithstanding any deviating minimum participation requirements provided for by that law. (3) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria a Contracting State is exempt from tax in that State, Austria such State may nevertheless, in calculating the amount of tax on the remaining income or capital 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paidcapital. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double 1. In the case of Jersey, double taxation shall be eliminated avoided as follows: (1a) In When imposing tax on its residents, Jersey may include in the case basis upon which such taxes are imposed the items of Austria:income, which, according to the provisions of this Agreement, may be taxed in the United Kingdom; ab) Where a resident of Austria Jersey derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in the United Kingdom, Austria Jersey shall allow as a deduction from the tax on the income of that resident, an amount equal to the income 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, attributable 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 Jersey tax payable under the laws of Austria Jersey and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Jersey (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 Jersey tax is computed; b) a dividend which is paid by a company which is a resident of Austria Jersey to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Jersey 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 sub-paragraph b) above which is paid by a company which is a resident of Austria Jersey to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Jersey tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and chargeable gains owned by a resident of a Contracting State one of the Territories which may be taxed in the other Contracting State Territory in accordance with this Convention Agreement shall be deemed to arise from sources in that other StateTerritory. 4. The provisions of paragraph 1 shall not apply where the United Kingdom tax payable is in accordance with the Agreement solely because the profits, income or chargeable gains referred to in that paragraph are also profits, income or chargeable gains derived by a resident of the United Kingdom. 5. The provisions of paragraph 2 of this Article shall not apply where the Jersey tax payable is in accordance with the Agreement solely because the profits, income or chargeable gains referred to in that paragraph are also profits, income or chargeable gains derived by a resident of Jersey.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In The laws of each of the case Contracting States shall continue to govern the taxation of Austria: a) income whether derived from the Contracting State or elsewhere except where express provisions to the contrary are made in this Convention. Where a resident income derived from one of Austria derives the Contracting States is subject to tax in both Contracting States, relief from tax chargeable on such income which, shall be given in accordance with the provisions of paragraphs (2) and (3) 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 incomearticle. (2) Subject to the provisions of the law of Cyprus regarding the allowance as a credit against Cyprus tax of tax payable in a territory outside Cyprus (which shall not affect the general principle hereof)-- (a) United Kingdom tax payable under the laws of the United Kingdom and in accordance with this Convention, whether directly or by deduction, on profits or income from sources within the United Kingdom shall be allowed as a credit against any Cyprus tax computed by reference to the same profits or income by reference to which the United Kingdom tax is computed. Provided that in the case of a dividend the credit shall only take into account such tax in respect thereof as is additional to any tax payable by the company on the profits out of which the dividend is paid and is ultimately borne by the recipient without reference to any tax so payable. (b) Where a company which is a resident of the United Kingdom pays a dividend to a company resident in Cyprus which controls directly or indirectly at least 10 per cent of the voting power of the first-mentioned company, the credit shall take into account (in addition to any United Kingdom tax for which credit may be allowed under the provisions of subparagraph (a) of this paragraph) the United Kingdom tax payable by that first-mentioned company in respect of the profits out of which such dividend is paid. (3) 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):hereof)-- (a) Austrian Cyprus tax payable under the laws of Austria Cyprus and in accordance with this Convention, whether directly or by deduction, on profits, profits or 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) Cyprus shall be allowed as a credit against any United Kingdom tax computed by reference to the same profits, profits or income or chargeable gains by reference to which the Austrian Cyprus tax is computed;. Provided that in the case of a dividend the credit shall only take into account such tax in respect thereof as is additional to any tax payable by the company on the profits out of which the dividend is paid and is ultimately borne by the recipient without reference to any tax so payable. (b) a dividend which is paid by Where a company which is a resident of Austria Cyprus pays a dividend to a company which is a resident of in 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividendfirst-mentioned company, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Cyprus tax for which credit may be allowed under the Austrian provisions of subparagraph (a) of this paragraph) the Cyprus tax payable by the first-mentioned company in respect of its the profits out of which such dividend is paid. (34) For the purposes purpose of paragraphs 1 (2) and 2, profits, (3) of this article profits and income and gains owned derived by a resident of a one of the Contracting State States which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise be derived from sources in that the other Contracting State. (5) For the purposes of paragraph (3) of this article, the term "Cyprus tax payable" shall be deemed to include-- (a) any amount which would have been payable as Cyprus tax for any year but for an exemption or reduction of tax granted for that year or any part thereof under Section 10 of the Income Tax Laws 1961 to 1969 of Cyprus (so far as it was in force on, and has not been modified since, the date of signature of this Convention, or has been modified only in minor respects so as not to affect its general character), in any case where the interest in question is certified by the competent authority of Cyprus as being payable in respect of a loan made for the purposes of promoting development in Cyprus; or (b) in the case of any approved capital expenditure, any amount which would have been payable as Cyprus tax but for an investment deduction allowed under Section 12(2)(b) or (c) of the Cyprus Income Tax Laws 1961 to 1969 (so far as they were in force on, and have not been modified since, the date of signature of this Convention or have been modified only in minor respects so as not to affect their general character). For the purposes of this subparagraph the term "approved capital expenditure" means capital expenditure which is incurred, on or after the date of signature of this Convention and not later than 5 years after the commencement of the trade or business in question, by an enterprise wholly or mainly engaged in the hotel business or in activities falling within one of the following classes: (i) manufacturing, assembling or processing; (ii) construction, civil engineering or shipbuilding; or (iii) electricity, hydraulic power, gas or water supply; and which is certified by the competent authority of Cyprus as incurred for the purposes of promoting development in Cyprus; or (c) any amount which would have been payable as Cyprus tax for any year but for an exemption or reduction of tax granted for that year or any part thereof under any other provision which may be made after the date of signature of this Convention granting an exemption or reduction of tax which is agreed by the competent authorities of the Contracting States to be of a substantially similar character, if it has not been modified thereafter or has been modified only in minor respects so as not to affect its general character.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of Austria: a) Where a resident of Austria Estonia derives income which, or owns capital gains which in accordance with the provisions of this Convention, may be taxed in the United Kingdom, Austria unless a more favourable treatment is provided in its domestic law, Estonia shall allow as a deduction from the tax on the income of that resident, an amount equal to the United Kingdom income tax on income or capital gains tax paid thereon in the United Kingdom; Such deduction in either case shall not, however, exceed that part of the income tax, tax in Estonia as computed before the deduction is given, which is attributable, as the case may be, attributable to the income or the capital gains which may be taxed in the United Kingdom. (b) Where in accordance with any provision For the purpose of the Convention income derived by sub-paragraph (a) of this paragraph, where a company that is a resident of Austria Estonia receives a dividend from a company that is exempt from resident of the United Kingdom in which it owns at least 10 per cent of its shares having full voting rights, the tax paid in that State, Austria may nevertheless, in calculating the amount of United Kingdom shall include not only the tax paid on the remaining income dividend, but also the tax paid on the underlying profits of such resident, take into account the exempted incomecompany out of which the dividend was paid. (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 Estonian tax payable under the laws of Austria Estonia and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Estonia (excluding in the case of a dividend dividend, tax payable in Estonia 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 Estonian tax is computed; (b) in the case of 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 is a resident of Austria Estonia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Estonian tax for which credit may be allowed under the Austrian provisions of sub-paragraph (a) of this paragraph) the Estonian tax payable by the company in respect of its the profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Convention, shall be deemed to arise from sources in that other Contracting State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case of Austria:Guernsey, double taxation shall be avoided as follows. Subject to the provisions of the laws of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey (which shall not affect the general principle hereof): a) Where subject to the provisions of sub-paragraph c), where a resident of Austria Guernsey derives income which, in accordance with the provisions of this Conventionthe Agreement, may be taxed in the United Kingdom, Austria Guernsey shall allow as a deduction from the tax on the income payable in respect of that residentincome, an amount equal to the income tax on income or capital gains paid in the United Kingdom; Such ; b) 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, attributable to the income or the capital gains which may be taxed in the United Kingdom.; bc) Where where a resident of Guernsey derives income which, in accordance with any provision the provisions of the Convention Agreement shall be taxable only in the United Kingdom, Guernsey may include this 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 Guernsey tax payable under the laws of Austria Guernsey and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Guernsey (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 Guernsey tax is computed; b) a dividend which is paid by a company which is a resident of Austria Guernsey to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Guernsey 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 sub-paragraph b) above which is paid by a company which is a resident of Austria Guernsey to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Guernsey tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and chargeable gains owned by a resident of a Contracting State one of the Territories which may be taxed in the other Contracting State Territory in accordance with this Convention Agreement shall be deemed to arise from sources in that other StateTerritory. 4. The provisions of paragraph 1 shall not apply where the United Kingdom tax payable is in accordance with the Agreement solely because the income referred to in that paragraph is also income derived by a resident of the United Kingdom. 5. The provisions of paragraph 2 shall not apply where the Guernsey tax payable is in accordance with the Agreement solely because the profits, income or chargeable gains referred to in that paragraph are also profits, income or chargeable gains derived by a resident of Guernsey.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of Austria: (a) Where a resident of Austria Georgia derives income or owns capital which, in accordance with the provisions of this ConventionAgreement, may be taxed in the United Kingdom, Austria Georgia shall allow allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the United Kingdom; (ii) as a deduction from the tax on income or the capital gains of that resident, an amount equal to the capital tax paid in the United Kingdom; Such deduction in either case shall not, however, exceed that part of the income tax or capital 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 KingdomGeorgia. (b) Where in accordance with any provision of the Convention Agreement income derived or capital owned by a resident of Austria Georgia is exempt from tax in that Statethe United Kingdom, Austria Georgia may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted incomeincome or capital. (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 Georgian tax payable under the laws of Austria Georgia and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Georgia (excluding in the case of a dividend 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 Georgian tax is computed; (b) in the case of 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 is a resident of Austria Georgia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Georgian tax for which credit may be allowed under the Austrian provisions of sub-paragraph (a) of this paragraph) the Georgian tax payable by the company in respect of its the profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and paragraph (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double 1. In Armenia, double taxation shall be eliminated avoided as follows: (1) In the case of Austria: a) Where where a resident of Austria Armenia derives income (including gains) or owns capital which, in accordance with the provisions of this Convention, may be taxed in the United Kingdom, Austria Armenia shall allow allow: (i) 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; ; (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in the United Kingdom. Such deduction in either case 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 this Convention, income derived or capital owned by a resident of Austria Armenia is exempt from tax in that StateArmenia, Austria Armenia may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted incomeincome or capital. (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 Armenian tax payable under the laws of Austria Armenia and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Armenia (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 Armenian tax is computed; b) a dividend which is paid by a company which is a resident of Austria Armenia 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) in the profits case of a permanent establishment in Austria of a company which is a resident of the United Kingdom shall be dividend not exempted from United Kingdom tax when the exemption is applicable and under sub-paragraph b) above (because the conditions for exemption under the law of the United Kingdom are not met; d) in the case of a dividend not exempted from tax under subparagraph b) above which is paid by a company which is a resident of Austria Armenia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Armenian tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case of Austria:the Isle of Man, double taxation shall be avoided as follows. Subject to the provisions of the laws of the Isle of Man regarding the allowance as a credit against Manx tax of tax payable in a territory outside the Isle of Man (which shall not affect the general principle hereof): a) Where subject to the provisions of sub-paragraph c), where a resident of Austria the Isle of Man derives income which, in accordance with the provisions of this Conventionthe Agreement, may be taxed in the United Kingdom, Austria the Isle of Man shall allow as a deduction from the tax on the income payable in respect of that residentincome, an amount equal to the income tax on income or capital gains paid in the United Kingdom; Such ; b) 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, attributable to the income or the capital gains which may be taxed in the United Kingdom.; bc) Where where a resident of the Isle of Man derives income which, in accordance with any provision the provisions of the Convention Agreement, shall be taxable only in the United Kingdom, the Isle of Man may include this income in the tax base, but shall allow as a deduction from the income tax that part of the income tax which is attributed to the 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 incomeUnited Kingdom. (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 Manx tax payable under the laws of Austria the Isle of Man and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria the Isle of Man (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 Manx tax is computed; b) a dividend which is paid by a company which is a resident of Austria the Isle of Man to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 the Isle of Man 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 sub-paragraph b) above which is paid by a company which is a resident of Austria the Isle of Man to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Manx tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and chargeable gains owned by a resident of a Contracting State one of the Territories which may be taxed in the other Contracting State Territory in accordance with this Convention Agreement shall be deemed to arise from sources in that other StateTerritory. 4. The provisions of paragraph 1 shall not apply where the United Kingdom tax payable is in accordance with the Agreement solely because the income referred to in that paragraph is also income derived by a resident of the United Kingdom. 5. The provisions of paragraph 2 shall not apply where the Manx tax payable is in accordance with the Agreement solely because the profits, income or chargeable gains referred to in that paragraph are also profits, income or chargeable gains derived by a resident of the Isle of Man.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows:‌ (1) . In the case of Austria:Guernsey, double taxation shall be avoided as follows. Subject to the provisions of the laws of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey (which shall not affect the general principle hereof): a) Where subject to the provisions of sub-paragraph c), where a resident of Austria Guernsey derives income which, in accordance with the provisions of this Conventionthe Agreement, may be taxed in the United Kingdom, Austria Guernsey shall allow as a deduction from the tax on the income payable in respect of that residentincome, an amount equal to the income tax on income or capital gains paid in the United Kingdom; Such ; b) 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, attributable to the income or the capital gains which may be taxed in the United Kingdom.; bc) Where where a resident of Guernsey derives income which, in accordance with any provision the provisions of the Convention Agreement shall be taxable only in the United Kingdom, Guernsey may include this 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 Guernsey tax payable under the laws of Austria Guernsey and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Guernsey (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 Guernsey tax is computed; b) a dividend which is paid by a company which is a resident of Austria Guernsey to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Guernsey 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 sub-paragraph b) above which is paid by a company which is a resident of Austria Guernsey to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Guernsey tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and chargeable gains owned by a resident of a Contracting State one of the Territories which may be taxed in the other Contracting State Territory in accordance with this Convention Agreement shall be deemed to arise from sources in that other StateTerritory. 4. The provisions of paragraph 1 shall not apply where the United Kingdom tax payable is in accordance with the Agreement solely because the income referred to in that paragraph is also income derived by a resident of the United Kingdom. 5. The provisions of paragraph 2 shall not apply where the Guernsey tax payable is in accordance with the Agreement solely because the profits, income or chargeable gains referred to in that paragraph are also profits, income or chargeable gains derived by a resident of Guernsey.

ELIMINATION OF DOUBLE TAXATION. 1. Double taxation shall be eliminated as follows: (1a) In in the case of Austria: a) Where Zambia, where a resident of Austria Zambia derives income which, from the United Kingdom which may be taxed in the United Kingdom in accordance with the provisions of this ConventionAgreement, may the amount of the United Kingdom tax payable in respect of that income shall be taxed allowed as a credit against Zambian tax imposed on that resident. The amount of credit, however, shall not exceed that part of Zambian tax which is appropriate to that income. (b) in the case of 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 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(i) Austrian Zambian tax payable under the laws of Austria Zambia and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Zambia (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 Zambian tax is computed; b(ii) a dividend which is paid by a company which is a resident of Austria Zambia 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(iii) the profits of a permanent establishment in Austria Zambia 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(iv) in the case of a dividend not exempted from tax under subparagraph b(ii) above which is paid by a company which is a resident of Austria Zambia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a(i) above shall also take into account the Austrian Zambian tax payable by the company in respect of its profits out of which such dividend is paid. (3) 2. For the purposes of paragraphs 1 and 2paragraph 1, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of Austria: a) . Where a resident of Austria Kosovo derives income which, in accordance with the provisions of this Convention, may be taxed in the United Kingdom, Austria Kosovo shall allow as a deduction from the tax on the income of that resident, 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, attributable 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 Kosovo tax payable under the laws of Austria Kosovo and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Kosovo (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 Kosovo tax is computed; b) a dividend which is paid by a company which is a resident of Austria Kosovo to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Kosovo 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 sub-paragraph b) above which is paid by a company which is a resident of Austria Kosovo to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Kosovo tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

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 Indonesian tax payable under the laws of Austria Indonesia and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Indonesia (excluding in the case of a dividend 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 Indonesian tax is computed; (b) in the case of 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 is a resident of Austria Indonesia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Indonesian tax for which credit may be allowed under the Austrian provisions of sub-paragraph (a) of this paragraph) the Indonesian tax payable by the company in respect of its the profits out of which such dividend is paid. (2) Where a resident of Indonesia derives income from the United Kingdom and such income may be taxed in the United Kingdom in accordance with the provisions of this Agreement, the amount of United Kingdom tax payable in respect of the income shall be allowed as a credit against the Indonesian tax imposed on that resident. The amount of credit, however, shall not exceed that part of the Indonesian tax which is appropriate to such income. (3) For the purposes of paragraph (1) of this Article, the term "Indonesian tax payable" shall be deemed to include any amount which would have been payable as Indonesian tax for any year but for an exemption or reduction of tax granted for the year or any part thereof under Article 15(5) and Article 16(1) and (2) of Law No 1 of 1967 of Indonesia to the extent that these provisions continue in force by virtue of Article 33(2)(a) of Act No 7 of 1983 of Indonesia. Provided that relief from United Kingdom tax shall not be given by virtue of this paragraph in respect of income from any source if the income arises in a period starting more than 10 years after the exemption from, or reduction of, Indonesian tax was first granted in respect of that source. (4) For the purposes of paragraphs 1 (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other Contracting State. (5) Where profits on which an enterprise of a Contracting State has been charged to tax in that State are also included in the profits of an enterprise of the other State and the profits so included are profits which would have accrued to that enterprise of the other State if the conditions made between the enterprises had been those which would have been made between independent enterprises dealing at arm's length, the amount included in the profits of both enterprises shall be treated for the purposes of this Article as income from a source in the other State of the enterprise of the first- mentioned State and relief shall be given accordingly under the provisions of paragraph (1) or paragraph (2) of this Article.

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 Unites Kingdom regarding the allowance as a credit against United Kingdom tax of tax tox 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 Indonesian tax payable under the laws of Austria Indonesia and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Indonesia (excluding in the case of a dividend 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 Indonesian tax is computed; (b) in the case of a dividend which is paid by bay 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 is a resident of Austria Indonesia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Indonesian tax for which credit may be allowed under the Austrian tax provisions of sub-paragraph (a) of this paragraph) the Indonesian tox payable by the company in respect of its the profits out of which such dividend is paid. (2) Where a resident of Indonesia derives income from the United Kingdom and such income may be taxed in the United Kingdom in accordance with the provisions of this Agreement, the amount of United Kingdom tax payable in respect of the income shall be allowed as a credit against the Indonesian tax imposed on that resident. The amount of credit, however, shall not exceed that part of the Indonesian tax which is appropriate to such income. (3) For the purposes of paragraphs paragraph (1) of this Article, the term "Indonesian tax payable" shall be deemed to include any amount which would have been payable as Indonesian tax for any year but for an exemption or reduction of tax granted for the year or any part thereof under Article 15 (5) and Article 16 (1) and (2) of Law No 1 of 1967 of Indonesia to the extent that these provisions continue in force by virtue of Article 33 (2) (a) of Act No 7 of 1983 of Indonesia. Provided that relief from United Kingdom tax shall not be given by virtue of this paragraph in respect of income from any source if the income arises in a period starting more than 10 years after the exemption from, or reduction of, Indonesian tax was first granted in respect of that source. (4) For the purposes of paragraph (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting Contacting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other Contracting State. (5) Where profits on which an enterprise of a Contracting State has been charged to tax in that State are also included in the profits of an enterprise of the other State and the profits so included are profits which would have accrued to that enterprise of the other State if the conditions made between the enterprises had been those which would have been made between independent enterprises dealing at arm's length, the amount included in the profits of both enterprises shall be treated for the purposes of this Article as income form a source in the other State of the enterprise of the first-mentioned State and relief shall be given accordingly under the provisions of paragraph (1) or paragraph (2) of this Article.

ELIMINATION OF DOUBLE TAXATION. Double 1. In Korea, double taxation shall be eliminated avoided as follows: : Subject to the provisions of Korean tax law regarding the allowance as credit against Korean tax of tax payable in any country other than Korea (1) In which shall not affect the case of Austria:general principle thereof): a) Where a resident of Austria Korea derives income which, from Peru which may be taxed in Peru under the laws of Peru in accordance with the provisions of this Convention, may in respect of that income, the amount of Peruvian tax payable shall be taxed in the United Kingdom, Austria shall allow allowed as a deduction from credit against the Korean tax payable imposed on the income of that resident, an . The amount equal to the tax on income or capital gains paid in the United Kingdom; Such deduction of credit shall not, however, exceed that part of the income tax, Korean tax as computed before the deduction credit is given, which is attributableappropriate to that income; b) Where the income derived from Peru is dividends paid by a company which is a resident of Peru to a company which is a resident of Korea which owns at least 10 per cent of the voting shares issued by or the capital stock of the company paying the dividends, the credit shall take into account the Peruvian tax payable by the company in respect of the profits out of which such dividend is paid. 2. In the case of Peru, double taxation shall be avoided as follows: a) Residents of Peru may credit against Peruvian income tax, as a credit, the case may beKorean tax payable on income taxed in accordance with the laws of Korea and the provisions of this Convention. Such credit shall not, in any case, exceed that part of the Peruvian income tax which is attributable to the income or the capital gains which may be taxed in the United Kingdom.Korea; b) Where a company which is a resident of Korea pays a dividend to a company which is a resident of Peru that controls directly or indirectly at least 10 per cent of the voting power in the former company, the credit shall take into account the tax payable in Korea by the company in respect of the profits out of which such dividend is paid but only to the extent that the Peruvian tax exceeds the amount of the credit determined without reference to this subparagraph; c) Where in accordance with any provision of the Convention income derived by a resident of Austria a Contracting State is exempt from tax in that State, Austria such State 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case territory in which the taxation laws administered by the Austrian Federal Ministry of AustriaFinance are applied: a) Where a resident of Austria the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in the United Kingdomterritory in which the taxation laws administered by the Ministry of Finance, Austria Taipei are applied, the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied shall, subject to the provisions of sub- paragraphs b) and c), exempt such income from tax. b) Where a resident of the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied derives items of income which, in accordance with the provisions of Articles 10, 11 and 12, may be taxed in the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied, the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the tax on income or capital gains paid in the United Kingdom; territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributableattributable to such items of income derived from the territory in which the taxation laws administered by the Ministry of Finance, as the case may be, to the income or the capital gains which may be taxed in the United KingdomTaipei are applied. bc) Where in accordance with any provision of the Convention Agreement income derived by a resident of Austria the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied is exempt from tax in that Statethe territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied, Austria the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. (2d) Subject The provisions of sub-paragraph a) shall not apply to income derived by a resident of the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied where the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied applies the provisions of this Agreement to exempt such income from tax or applies the law provisions of paragraph 2 of Article 10, 11 or 12 to such income. 2. In the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied: Where a resident of the United Kingdom regarding territory in which the allowance as a credit against United Kingdom tax taxation laws administered by the Ministry of Finance, Taipei are applied derives income from the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied, the amount of tax payable on that income paid in a the territory outside in which the United Kingdom ortaxation laws administered by the Austrian Federal Ministry of Finance are applied (but excluding, 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 dividend, tax payable paid 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with the provisions of this Convention Agreement, shall be deemed to arise from sources credited against the tax levied in the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied imposed on that other Stateresident. The amount of credit, however, shall not exceed the amount of the tax in the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied on that income computed in accordance with its taxation laws and regulations.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case of AustriaSweden, double taxation shall be avoided as follows: a) Where a resident of Austria Sweden derives income which under the laws of the United Kingdom and in accordance with the provisions of this Convention may be taxed in the United Kingdom, Sweden shall allow - subject to the provisions of the laws of Sweden concerning credit for foreign tax (as they may be amended from time to time without changing the general principle hereof) - as a deduction from the tax on such income, an amount equal to the United Kingdom tax paid in respect of such income. b) Where a resident of Sweden derives income which, in accordance with the provisions of this Convention, may shall be taxed taxable only in the United Kingdom, Austria shall allow as a deduction from Sweden may, when determining the tax on graduated rate of Swedish tax, take into account the income of that resident, an amount equal to the tax on income or capital gains paid in the United Kingdom; Such deduction which 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 taxable only in the United Kingdom. bc) Where in accordance with any provision Notwithstanding the provisions of the Convention income derived subparagraph a) of this paragraph, dividends paid by a company which is a resident of Austria the United Kingdom to a company which is a resident of Sweden shall be exempt from Swedish tax in that State, Austria may nevertheless, in calculating according to the amount provisions of Swedish law governing the exemption of tax on the remaining income of such resident, take into account the exempted incomedividends paid to Swedish companies by companies abroad. (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 Swedish tax payable under the laws of Austria Sweden and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Sweden (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 Swedish tax is computed; b) a dividend which is paid by a company which is a resident of Austria Sweden to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Sweden 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 is a resident of Austria Sweden to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian Swedish tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State. 4. here a resident of a Contracting State derives gains which may be taxed in the other Contracting State under the provisions of paragraph 6 of Article 13, and those gains are in respect of: a) shares or comparable interests referred to in paragraph 2 of Article 13, and the immovable property in question is situated in the first-mentioned Contracting State, or b) shares referred to in paragraph 7 of Article 26, and the rights in question are to assets to be produced by the exploration or exploitation of the sea- bed and subsoil and their natural resources situated in the first-mentioned Contracting State that other Contracting State shall allow, under the provisions of paragraphs 1 or 2, as the case may be, a deduction of, or a credit for, the tax paid on that gain in the first-mentioned Contracting State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of Austria: a) Where a resident of Austria Lithuania derives income which, or capital gains which in accordance with the provisions of this Convention, may be taxed in the United Kingdom, Austria unless a more favourable 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 United Kingdom income tax, corporation tax on income or capital gains tax paid thereon in the United Kingdom; . Such deduction shall not, however, exceed that part of the income tax, tax in Lithuania as computed before the deduction is given, which is attributable, 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 For the purpose of the Convention income derived by sub-paragraph (a) of this paragraph, where a company that is a resident of Austria Lithuania receives a dividend from a company that is exempt from a resident of the United Kingdom in which it owns at least 10 per cent of its shares having full voting rights, the tax paid in that State, Austria may nevertheless, in calculating the amount of United Kingdom shall include not only the tax paid on the remaining income dividend, but also the tax paid on the underlying profits of such resident, take into account the exempted incomecompany out of which the dividend was paid. (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 Lithuanian tax payable under the laws of Austria Lithuania and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Lithuania (excluding in the case of a dividend dividend, tax payable in Lithuania 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 Lithuania tax is computed; (b) in the case of 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 is a resident of Austria Lithuania to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Lithuanian tax for which credit may be allowed under the Austrian provisions of sub-paragraph (a) of this paragraph) the Lithuanian tax payable by the company in respect of its the profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Convention, shall be deemed to arise from sources in that other Contracting State.

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 Unites Kingdom regarding the allowance as a credit against United Kingdom tax of tax tox 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 Indonesian tax payable under the laws of Austria Indonesia and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Indonesia (excluding in the case of a dividend 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 Indonesian tax is computed; (b) in the case of a dividend which is paid by bay 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 is a resident of Austria Indonesia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Indonesian tax for which credit may be allowed under the Austrian tax provisions of sub- paragraph (a) of this paragraph) the Indonesian tox payable by the company in respect of its the profits out of which such dividend is paid. (2) Where a resident of Indonesia derives income from the United Kingdom and such income may be taxed in the United Kingdom in accordance with the provisions of this Agreement, the amount of United Kingdom tax payable in respect of the income shall be allowed as a credit against the Indonesian tax imposed on that resident. The amount of credit, however, shall not exceed that part of the Indonesian tax which is appropriate to such income. (3) For the purposes of paragraphs paragraph (1) of this Article, the term "Indonesian tax payable" shall be deemed to include any amount which would have been payable as Indonesian tax for any year but for an exemption or reduction of tax granted for the year or any part thereof under Article 15 (5) and Article 16 (1) and (2) of Law No 1 of 1967 of Indonesia to the extent that these provisions continue in force by virtue of Article 33 (2) (a) of Act No 7 of 1983 of Indonesia. Provided that relief from United Kingdom tax shall not be given by virtue of this paragraph in respect of income from any source if the income arises in a period starting more than 10 years after the exemption from, or reduction of, Indonesian tax was first granted in respect of that source. (4) For the purposes of paragraph (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting Contacting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other Contracting State. (5) Where profits on which an enterprise of a Contracting State has been charged to tax in that State are also included in the profits of an enterprise of the other State and the profits so included are profits which would have accrued to that enterprise of the other State if the conditions made between the enterprises had been those which would have been made between independent enterprises dealing at arm's length, the amount included in the profits of both enterprises shall be treated for the purposes of this Article as income form a source in the other State of the enterprise of the first- mentioned State and relief shall be given accordingly under the provisions of paragraph (1) or paragraph (2) of this Article.

ELIMINATION OF DOUBLE TAXATION. Double 1. In Chile, double taxation shall be eliminated avoided as follows: (1) In the case of Austriafollows : a) Where a resident Residents of Austria derives Chile, obtaining income whichwhich has, in accordance with the provisions of this Convention, been subject to taxation in Belgium, may be taxed in the United Kingdom, Austria shall allow as a deduction from credit the tax on so paid against any Chilean tax payable in respect of the income of that residentsame income, an amount equal subject to the tax on income or capital gains paid in the United Kingdom; Such deduction shall not, however, exceed that part applicable provisions of the law of Chile. This paragraph shall apply to all income tax, as computed before the deduction is given, which is attributable, as the case may be, referred to the income or the capital gains which may be taxed in the United Kingdomthis Convention. b) Where Where, in accordance with any provision of the Convention Convention, income derived or capital owned by a resident of Austria Chile is exempt from tax in that StateChile, Austria Chile may nevertheless, in calculating the amount of tax on other income or capital, take into account the exempted income or capital. 2. In Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, or owns elements of capital which may be taxed in Chile in accordance with the provisions of this Convention, and which are taxed there, Belgium shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of such that resident, take into account apply 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 rate 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, would have been applicable if such income or chargeable gains from sources within Austria (excluding in the case elements 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;capital had not been exempted. b) a dividend which is paid Dividends derived by a company which is a resident of Austria to Belgium from a company which is a resident of the United Kingdom Chile, shall be exempted exempt from United Kingdom tax, when the exemption is applicable corporate income tax in Belgium under the same conditions and within the same limits as if the company paying the dividends was a resident of Belgium or of another member State of the European Union. For the application of the conditions for exemption under and limits referred to in this provision, the law total amount of the United Kingdom are met; c) taxes paid on the profits out of a permanent establishment in Austria which the dividends were paid to the resident of Belgium, including the Additional Tax, shall be taken into consideration. Where a company which is a resident of the United Kingdom shall be exempted Belgium derives 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 is a resident of Austria Chile dividends which are not exempt from the corporate income tax in Belgium, Belgium shall deduct from the Belgian tax relating to a company these dividends the Chilean tax (namely the Additional Tax after deduction of the First Category Tax) levied on these dividends. This deduction shall not exceed that part of the Belgian tax which is proportionally relating to these dividends. c) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of the United Kingdom and Belgium derives items of his aggregate income for Belgian tax purposes which controls directly are interest or indirectly at least 10 per cent of the voting power in the company paying the dividendroyalties, the Chilean tax levied on that income shall be allowed as a credit mentioned in subparagraph a) above shall also take into account the Austrian against Belgian tax payable by the company in respect of its profits out of which relating to such dividend is paidincome. (3d) For the purposes of paragraphs 1 and 2Where, profitsin accordance with Belgian law, income and gains owned losses incurred by an enterprise carried on by a resident of Belgium in a Contracting State which may be taxed permanent establishment situated in Chile, 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 Contracting State taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in accordance with this Convention shall be deemed to arise from sources in that other StateChile by reason of compensation for the said losses.

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 principal hereof): (a) Austrian Trinidad and Tobago tax payable under the laws of Austria Trinidad and Tobago and in accordance with this Convention, whether directly or by deduction, on profits, profits or income or chargeable gains from sources within Austria Trinidad and Tobago (excluding in the case of a dividend 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, profits or income or chargeable gains by reference to which the Austrian Trinidad and Tobago tax is computed;. (b) In the case of 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 Trinidad 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 is a resident of Austria Tobago to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Trinidad and Tobago tax for which credit may be allowed under the Austrian provisions of sub-paragraph (a) of this paragraph) the Trinidad and Tobago tax payable by the company in respect of its the profits out of which such dividend is paid. (2) For the purposes of paragraph (1) of this Article, the term "Trinidad and Tobago tax payable" shall be deemed to include any amount which would have been payable as Trinidad and Tobago tax for any year but for an exemption from, or reduction of, tax granted for that year or any part thereof under any of the following provisions of Trinidad and Tobago law: (i) The Fiscal Incentives Act, 1979 (Act No. 22 of 1979); (ii) Housing Xxx 0000; (iii) Hotel Xxxxxxxxxxx Xxx, 0000; so far as they were in force in, and have not been modified since, the date of signature of this Convention, or have been modified only in minor respects so as not to affect their general character; or (b) any other provision which may subsequently be made granting an exemption from or reduction of tax which is agreed by the competent authorities of the Contracting States to be of a substantially similar character, if it has not been modified thereafter or has been modified only in minor respects so as not to affect its general character. Provided (c) that relief from United Kingdom tax shall not be given by virtue of this paragraph in respect of income from any source if the income arises in a period starting more than ten years after the exemption from, or reduction of, Trinidad and Tobago tax was first granted in respect of that source. (3) Subject to the provisions of the law of Trinidad and Tobago regarding the allowance as a credit against Trinidad and Tobago tax of tax payable in a territory outside Trinidad and Tobago (which shall not affect the general principle hereof), the United Kingdom tax payable under the laws of the United Kingdom and in accordance with this Convention (excluding in the case of a dividend, tax payable on the profits or income of the company paying the dividend) whether by deduction from, or under a computation measured by reference to, profits or income from sources within the United Kingdom shall be allowed as a credit against any Trinidad and Tobago tax computed by reference to the same profits or income by reference to which the United Kingdom tax is computed. Where such income is a dividend paid by a company which is a resident of the United Kingdom to a company which is a resident of Trinidad and Tobago and which controls directly or indirectly not less than 10 per cent of the voting power in the United Kingdom company, the credit shall take into account (in addition to any United Kingdom tax payable in respect of the dividend) the United Kingdom tax payable by the company in respect of its profits. (4) For the purposes of paragraphs 1 (1) and 2, profits, (3) of this Article profits and income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other Contracting State. (5) Nothing in this Article shall entitle a person who is a resident of a Contracting State to credit against tax of that Contracting State of tax of the other Contracting State if the terms of the transactions giving rise to the profits on which the tax of the other Contracting State is payable are not such as might be expected in a bona fide commercial transaction and if they have as their main object or one of their main objects, the obtaining of that credit.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case territory in which the taxation laws administered by the Austrian Federal Ministry of AustriaFinance are applied: a) Where a resident of Austria the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in the United Kingdomterritory in which the taxation laws administered by the Ministry of Finance, Austria Taipei are applied, the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied shall, subject to the provisions of sub- paragraphs b) and c), exempt such income from tax. b) Where a resident of the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied derives items of income which, in accordance with the provisions of Articles 10, 11 and 12, may be taxed in the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied, the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the tax on income or capital gains paid in the United Kingdom; territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributableattributable to such items of income derived from the territory in which the taxation laws administered by the Ministry of Finance, as the case may be, to the income or the capital gains which may be taxed in the United KingdomTaipei are applied. bc) Where in accordance with any provision of the Convention Agreement income derived by a resident of Austria the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied is exempt from tax in that Statethe territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied, Austria the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. (2d) Subject The provisions of sub-paragraph a) shall not apply to income derived by a resident of the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied where the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied applies the provisions of this Agreement to exempt such income from tax or 2. In the law territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied: Where a resident of the United Kingdom regarding territory in which the allowance as a credit against United Kingdom tax taxation laws administered by the Ministry of Finance, Taipei are applied derives income from the territory in which the taxation laws administered by the Austrian Federal Ministry of Finance are applied, the amount of tax payable on that income paid in a the territory outside in which the United Kingdom ortaxation laws administered by the Austrian Federal Ministry of Finance are applied (but excluding, 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 dividend, tax payable paid 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with the provisions of this Convention Agreement, shall be deemed to arise from sources credited against the tax levied in the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied imposed on that other Stateresident. The amount of credit, however, shall not exceed the amount of the tax in the territory in which the taxation laws administered by the Ministry of Finance, Taipei are applied on that income computed in accordance with its taxation laws and regulations.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of Austria: a) . Where a resident of Austria San Marino derives income which, or gains which may be taxed in the United Kingdom in accordance with the provisions of this Convention, may be taxed in Convention (except to the extent that these provisions allow taxation by the United Kingdom solely because the income is also income derived by a resident of the United Kingdom), Austria San Marino shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax on income or capital gains tax paid in the United Kingdom; . Such deduction in either case 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 San Marino tax payable under the laws of Austria San Marino and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria San Marino (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 San Marino tax is computed; b) a dividend which is paid by a company which is a resident of Austria San Marino to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 San Marino 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 sub-paragraph b) above which is paid by a company which is a resident of Austria San Marino to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian San Marino tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2this paragraph, profits, income and gains owned by a resident of a Contracting State the United Kingdom which may be taxed in the other Contracting State San Marino in accordance with this Convention shall be deemed to arise from sources in San Marino. 3. The provisions of paragraph 2 shall not apply where San Marino tax payable is in accordance with the provisions of this Convention solely because the income, profits or chargeable gains referred to in that other paragraph is also income derived by a resident of San Marino. 4. Where in accordance with any provision of the Convention income derived by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of AustriaGibraltar, double taxation shall be avoided as follows: (a) Where when imposing tax on its residents, Gibraltar may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in the United Kingdom; (b) where a resident of Austria Gibraltar derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in the United Kingdom, Austria Gibraltar shall allow as a deduction from the tax on the income of that resident, an amount equal to the lesser of the Gibraltar tax due under the laws of Gibraltar or the United Kingdom tax due on that same income or capital gains paid in under the laws of 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 Gibraltar tax payable under the laws of Austria Gibraltar and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Gibraltar (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 Gibraltar tax is computed; (b) a dividend which is paid by a company which is a resident of Austria Gibraltar to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Gibraltar 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 of this paragraph which is paid by a company which is a resident of Austria Gibraltar to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph (a) above of this paragraph shall also take into account the Austrian Gibraltar tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2this paragraph, profits, income and gains owned by a resident of a Contracting State the United Kingdom which may be taxed in the other Contracting State Gibraltar in accordance with this Convention Agreement shall be deemed to arise from sources in Gibraltar. (3) The provisions of paragraph (1) shall not apply where the United Kingdom tax payable is in accordance with the provisions of this Agreement solely because the income referred to in that other Stateparagraph is also income, profits or chargeable gains derived by a resident of the United Kingdom. (4) The provisions of paragraph (2) shall not apply where the Gibraltar tax payable Back to Top is in accordance with the provisions of this Agreement solely because the income, profits or chargeable gains referred to in that paragraph is also income derived by a resident of Gibraltar.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case of AustriaSweden, double taxation shall be avoided as follows: a) Where a resident of Austria Sweden derives income which under the laws of the United Kingdom and in accordance with the provisions of this Convention may be taxed in the United Kingdom, Sweden shall allow - subject to the provisions of the laws of Sweden concerning credit for foreign tax (as they may be amended from time to time without changing the general principle hereof) - as a deduction from the tax on such income, an amount equal to the United Kingdom tax paid in respect of such income. b) Where a resident of Sweden derives income which, in accordance with the provisions of this Convention, may shall be taxed taxable only in the United Kingdom, Austria shall allow as a deduction from Sweden may, when determining the tax on graduated rate of Swedish tax, take into account the income of that resident, an amount equal to the tax on income or capital gains paid in the United Kingdom; Such deduction which 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 taxable only in the United Kingdom. bc) Where in accordance with any provision Notwithstanding the provisions of the Convention income derived subparagraph a) of this paragraph, dividends paid by a company which is a resident of Austria the United Kingdom to a company which is a resident of Sweden shall be exempt from Swedish tax in that State, Austria may nevertheless, in calculating according to the amount provisions of Swedish law governing the exemption of tax on the remaining income of such resident, take into account the exempted incomedividends paid to Swedish companies by companies abroad. (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 Swedish tax payable under the laws of Austria Sweden and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Sweden (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 Swedish tax is computed; b) a dividend which is paid by a company which is a resident of Austria Sweden to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, 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 Sweden 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 is a resident of Austria Sweden to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian Swedish tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State. 4. Where a resident of a Contracting State derives gains which may be taxed in the other Contracting State under the provisions of paragraph 6 of Article 13, and those gains are in respect of: a) shares or comparable interests referred to in paragraph 2 of Article 13, and the immovable property in question is situated in the first- mentioned Contracting State, or b) shares referred to in paragraph 7 of Article 26, and the rights in question are to assets to be produced by the exploration or exploitation of the sea-bed and subsoil and their natural resources situated in the first-mentioned Contracting State that other Contracting State shall allow, under the provisions of paragraphs 1 or 2, as the case may be, a deduction of, or a credit for, the tax paid on that gain in the first- mentioned Contracting State.

ELIMINATION OF DOUBLE TAXATION. Double 1. In the case of Iceland, double taxation shall be eliminated avoided as follows: (1) In the case of Austria: a) Where When a resident of Austria Iceland derives income which, in accordance with the provisions of this Convention, may be taxed in the United Kingdom, Austria Iceland shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income tax on income or capital gains paid in the United Kingdom; ; b) 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, attributable to the income or the capital gains which that may be taxed in the United Kingdom.; bc) Where When a resident of Iceland derives income which, in accordance with any provision the provisions of this Convention, shall be taxable only in the United Kingdom, Iceland may include this income in the tax base but shall allow as a deduction from income tax that part of the Convention income tax which is attributable to the 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 incomeUnited Kingdom. (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 Icelandic tax payable under the laws of Austria Iceland and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Iceland (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 Iceland tax is computed; b) a dividend which is paid by a company which is a resident of Austria Iceland 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 Iceland 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 sub-paragraph b) above which is paid by a company which is a resident of Austria Iceland to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub- paragraph a) above shall also take into account the Austrian Icelandic tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) In the case of Austria: a) Where Botswana, double taxation shall be avoided as follows: subject to the provisions of the law of Botswana regarding the allowance of a resident credit against Botswana tax of Austria derives tax payable under the laws of a country outside Botswana, United Kingdom tax payable under the laws of the United Kingdom and in accordance with this Convention, whether directly or by deduction, on profits, income whichor chargeable gains liable to tax in the United Kingdom shall be allowed as a credit against any Botswana tax payable in respect of the same profits, income or chargeable gains by reference to which the United Kingdom tax is computed. However, the amount of such credit shall not exceed the amount of the Botswana tax payable on that profits, income or chargeable gains in accordance with the provisions laws 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 incomeBotswana. (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 Botswana tax payable under the laws of Austria Botswana and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Botswana (excluding in the case of a dividend 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 Botswana tax is computed; (b) in the case of 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 is a resident of Austria Botswana to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Botswana tax for which credit may be allowed under the Austrian provisions of sub-paragraph (a) of this paragraph) the Botswana tax payable by the company in respect of its the profits out of which such dividend is paid. (3) For the purposes of paragraph (1) of this Article, where a development approval order is made under Section 52 or a tax agreement is entered into under Section 54 of the provisions of the Income Tax Act of Botswana, the term “Botswana tax payable” shall, subject to the mutual agreement of the competent authorities in each such case, be deemed to include the whole or part of any amount which would have been payable as Botswana tax for any year but for an exemption or reduction of tax granted for that year or any part thereof under the order or tax agreement in question. (4) Relief from United Kingdom tax by virtue of paragraph (3) of this Article shall not be given where the profits, income or chargeable gains in respect of which tax would have been payable but for the exemption or reduction of tax granted under the provisions referred to in that paragraph arise or accrue more than twelve years after the date on which this Convention enters into force. (5) The period referred to in paragraph (4) of this Article may be extended by agreement between the Contracting States. (6) For the purposes of paragraphs 1 (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other Contracting State.

ELIMINATION OF DOUBLE TAXATION. Double taxation shall be eliminated as follows: (1) . In the case of Austria: a) Colombia, double taxation shall be avoided as follows: Where a resident of Austria Colombia derives income which, in accordance with the provisions of this Convention, may be taxed in the United Kingdomother Contracting State, Austria Colombia shall allow as allow, subject to the limitations of provided for by its internal law: a) a deduction from the income tax on the income of that resident, effectively paid by such resident in an amount equal to the income tax paid in Korea; b) in the case of dividends, Colombia shall allow a deduction on income or capital gains paid tax equivalent to multiplying the total amount of the dividends by the rate of income tax applicable to the profits out of which such dividends are paid. When such dividends are taxed in the United Kingdom; other Contracting State, such deduction will be increased in the corresponding amount. However, in no case may such deduction exceed the total amount of income tax accrued in Colombia by such dividends. Such deduction shall not, however, exceed that part of the income taxtax on the income, as computed before the deduction is given, which is attributable, as the case may be, attributable to the such items of income or the capital gains which may be taxed in that other Contracting State. 2. In the United Kingdom.case of Korea, double taxation shall be avoided as follows: Subject to the provisions of Korean tax law regarding the allowance as credit against Korean tax of tax payable in any country other than Korea (which shall not affect the general principle thereof): a) Where a resident of Korea derives income from Colombia which may be taxed in Colombia under the laws of Colombia in accordance with the provisions of the Convention, in respect of that income, the amount of Colombian tax payable shall be allowed as a credit against the Korean tax payable imposed on that resident. The amount of credit shall not, however, exceed that part of Korean tax as computed before the credit is given, which is appropriate to that income; b) Where the income derived from Colombia is dividends paid by a company which is a resident of Colombia to a company which is a resident of Korea which owns at least 10 per cent of the voting shares issued by the company paying the dividends, the credit shall take into account the Colombian tax payable by the company in respect of the profits out of which such dividend is paid. 3. Where in accordance with any provision of the this Convention income derived by a resident of Austria a Contracting State is exempt from tax in that State, Austria such State 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

ELIMINATION OF DOUBLE TAXATION. Double 1. In the case of Trinidad and Tobago, double taxation shall be eliminated avoided as follows: a) Subject to the provisions of the laws of Trinidad and Tobago regarding the allowance of a credit against Trinidad and Tobago tax of tax payable in a territory outside Trinidad and Tobago (1which shall not affect the general principle hereof): (i) Spanish tax payable under the laws of Spain and in accordance with this Convention, whether directly by deduction on profits or income from sources within Spain (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 Trinidad and Tobago tax computed by reference to the same profits or income by reference to which the Spanish tax is computed; (ii) in the case of a dividend paid by a company which is a resident of Spain to a company which is a resident of Trinidad and Tobago and which controls directly or indirectly at least 25 percent of the voting power in the company paying the dividends the credit shall take into account, in addition to any Spanish tax creditable under (a) (i) the Spanish tax payable by the company paying the dividends in respect of the profits out of which such dividend is paid. b) The credit, however, shall in no case exceed that part of the tax, as computed before the credit is given, which is appropriate to the income which may be taxed in Spain. 2. In the case of AustriaSpain, double taxation shall be avoided following either the provisions of its internal legislation or the following provisions in accordance with the internal legislation of Spain: a) Where a resident of Austria Spain derives income which, in accordance with the provisions of this Convention, may be taxed in the United KingdomTrinidad and Tobago, Austria Spain shall allow allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax on income or capital gains paid in Trinidad and Tobago; (ii) the United Kingdom; deduction of the underlying corporation tax shall be given in accordance with the internal legislation of Spain. Such deduction shall not, however, exceed that part of the income tax, 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 KingdomTrinidad and Tobago. b) Where in accordance with any provision of the Convention income derived by a resident of Austria Spain is exempt from tax in that StateSpain, Austria Spain 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 is a resident of Austria to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian tax payable by the company in respect of its profits out of which such dividend is paid. (3) For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

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 Indonesian tax payable under the laws of Austria Indonesia and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Indonesia (excluding in the case of a dividend 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 Indonesian tax is computed; ; (b) in the case of 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 is a resident of Austria Indonesia to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent 10% of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account (in addition to any Indonesian tax for which credit may be allowed under the Austrian provisions of subparagraph (a) of this paragraph) the Indonesian tax payable by the company in respect of its the profits out of which such dividend is paid. 2. Where a resident of Indonesia derives income from the United Kingdom and such income may be taxed in the United Kingdom in accordance with the provisions of this Agreement, the amount of United Kingdom tax payable in respect of the income shall be allowed as a credit against the Indonesian tax imposed on that resident. The amount of credit, however, shall not exceed that part of the Indonesian tax which is appropriate to such income. 3. For the purposes of paragraph 1 of this Article, the term "Indonesian tax payable" shall be deemed to include any amount which would have been payable as Indonesian tax for any year but for an exemption or reduction of tax granted for the year or any part thereof under Article 15(5) and Article 16(1) and (32) of Law No. 1 of 1967 of Indonesia to the extent that these provisions continue in force by virtue of Article 33(2)(a) of Act Xx. 0 xx 0000 xx Xxxxxxxxx. Provided that relief from United Kingdom tax shall not be given by virtue of this paragraph in respect of income from any source if the income arises in a period starting more than 10 years after the exemption from, or reduction of, Indonesian tax was first granted in respect of that source. 4. For the purposes of paragraphs 1 and 22 of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other Contracting State. 5. Where profits on which an enterprise of a Contracting State has been charged to tax in that State are also included in the profits of an enterprise of the other State and the profits so included are profits which would have accrued to that enterprise of the other State if the conditions made between the enterprises had been those which would have been made between independent enterprises dealing at arm's length, the amount included in the profits of both enterprises shall be treated for the purposes of this Article as income from a source in the other State of the enterprise of the first-mentioned State and relief shall be given accordingly under the provisions of paragraph 1 or paragraph 2 of this Article.

ELIMINATION OF DOUBLE TAXATION. Double 1. In Spain, double taxation shall be eliminated as follows: (1) In avoided following either the case provisions of Austriaits internal legislation or the following provisions in accordance with the internal legislation of Spain: a) Where a resident of Austria Spain derives income or owns elements of capital which, in accordance with the provisions of this Convention, may be taxed in the United Kingdom, Austria Spain shall allow allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax on income or capital gains paid in the United Kingdom; ; (ii) as a deduction from the tax on the capital of that resident, an amount equal to the tax paid in the United Kingdom on the same elements of capital; (iii) the deduction of the underlying corporation tax, which shall be given in accordance with the internal legislation of Spain. Such deduction shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the same elements of capital gains which may be taxed in the United Kingdom. b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Austria Spain is exempt from tax in that StateSpain, Austria Spain may nevertheless, in calculating the amount of tax on the remaining income (or capital) of such resident, take into account the exempted incomeincome or capital. (2) . Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against the 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 arising in a territory outside the United Kingdom (which shall not affect the general principle hereof): a) Austrian Spanish tax payable under the laws of Austria Spain and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Spain (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 Spain’s tax is computed; b) a dividend which is paid by a company which is a resident of Austria Spain 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 Spain of a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax when taxation where 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 is a resident of Austria Spain to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph a) above shall also take into account the Austrian Spanish tax payable by the company in respect of its profits out of which such dividend is paid. (3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.

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 Albanian tax payable under the laws of Austria Albania and in accordance with this ConventionAgreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Austria Albania (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 Albanian tax is computed; b) a dividend which is paid by a company which is a resident of Austria Albania 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) in the profits case of a permanent establishment in Austria of a company which is a resident of the United Kingdom shall be dividend not exempted from United Kingdom tax when the exemption is applicable and under sub-paragraph b) above (because the conditions for exemption under the law of the United Kingdom are not met; d) in the case of a dividend not exempted from tax under subparagraph b) above which is paid by a company which is a resident of Austria Albania to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph sub-paragraph a) above shall also take into account the Austrian Albanian tax payable by the company in respect of its profits out of which such dividend is paid. (2. In Albania: a) Where a resident of Albania derives income or owns capital which, in accordance with the provisions of this Agreement may be taxed in the United Kingdom, Albania shall allow: i) as a deduction from Albanian tax on the income of that resident an amount equal to the income tax paid in the United Kingdom; and ii) as a deduction from Albanian tax on the capital of that resident, an amount equal to the capital tax paid in the United Kingdom Such deduction in either case shall not, however, exceed that part of the Albanian tax on income or on capital as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in the United Kingdom. b) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Albania is exempt from tax in Albania, Albania 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. 3) . For the purposes of paragraphs 1 and 2, profits, income and gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention Agreement shall be deemed to arise from sources in that other State.