Common use of ELIMINATION OF DOUBLE TAXATION Clause in Contracts

ELIMINATION OF DOUBLE TAXATION. 1. In Luxembourg double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Singapore, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (e), exempt such income or capital from tax. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 and 20 may be taxed in Singapore, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore. (c) For the purposes of sub-paragraph (b) of paragraph 1 the term "tax paid in Singapore" shall be deemed to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg tax payable, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Singapore and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paid.

ELIMINATION OF DOUBLE TAXATION. 1. In Luxembourg Singapore, double taxation shall be eliminated avoided as follows: (a) Where a resident of Luxembourg Singapore derives income or owns capital from France which, in accordance with the provisions of this AgreementConvention, may be taxed in SingaporeFrance, Luxembourg Singapore shall, subject to the provisions conditions of sub-paragraphs (b), (c), (d) and (e)exemption for income received from outside Singapore provided for in the Singapore Income Tax Act being satisfied, exempt such income or capital from tax.tax in Singapore; or (b) Where a resident of Luxembourg Singapore derives items of income from France which, in accordance with the provisions of Articles 8this Convention, 10, 11, 12 and 20 may be taxed in Singapore, Luxembourg shall allow as a deduction from the tax on France and the income of that resident an amount equal does not meet the conditions for exemption in Singapore referred to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore. (c) For the purposes of sub-paragraph (b) of paragraph 1 the term "tax paid in Singapore" shall be deemed a), Singapore shall, subject to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore its laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg allow the French tax payablepaid, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against the Singapore tax payable in respect on the income of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of incomeresident. (c) Notwithstanding paragraphs (a) and (b), (i) Where such income is a dividend dividends paid by a company which is a resident of Luxembourg to a company which is being a resident of Singapore and which owns directly by a company being a resident of France shall be exempted from Singapore tax if at least 10 per cent of the capital of the company resident of France is owned directly by the company resident of Singapore; (ii) profits attributable to a permanent establishment situated in France of an enterprise of Singapore and remitted to Singapore shall be exempted from Singapore tax. 2. In the case of a resident of France: (a) notwithstanding any other provision of this Convention, income which may be taxed or shall be taxable only in Singapore in accordance with the provisions of the Convention shall be taken into account for the computation of the French tax where such income is not exempted from French corporation tax according to paragraph (b) or to French domestic law. In that case, the Singapore tax shall not be deductible from such income, but the resident of France who is the beneficial owner shall, subject to the conditions and limits provided for in sub-paragraphs (i) and (ii), be entitled to a tax credit against French tax. Such tax credit shall be equal: (i) in the firstcase of income other than that mentioned in sub-mentioned companyparagraph (ii), to the amount of French tax attributable to such income provided that the resident of France is subject to Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion such income; (ii) in the case of income subject to the corporation tax referred to in Article 7 and paragraph 2 of Article 13 and in the case of income referred to in paragraph 2 of Article 10, paragraph 2 of Article 11, paragraph 3 of Article 12, paragraphs 1 and 3 of Article 13, Article 15, paragraphs 1 and 3 of Article 16, and paragraph 3 of Article 21 to the amount of tax paid in Singapore in accordance with the provisions of those Articles; however, such tax credit shall not exceed the amount of French tax attributable to such income. (b) (i) Dividends paid to a company being a resident of France by a company being a resident of Singapore shall be exempted from French corporation tax if at least 10 per cent of the profits out capital of which the dividend company resident of Singapore is paid.owned directly by the company resident of France;

ELIMINATION OF DOUBLE TAXATION. 1. In Luxembourg double taxation accordance with the provisions and subject to the limitations of the laws of Mexico, as may be amended from time to time without changing the general principle hereof, Mexico shall be eliminated allow its residents as followsa credit against the Mexican income tax: (a) the income tax paid to Singapore by or on behalf of such resident; and (b) in the case of a company owning at least 10% of the voting stock of a company which is a resident of Singapore and from which the first-mentioned company receives dividends, the income tax paid to Singapore or on behalf of the distributing company with respect to the profits out of which the dividends are paid. 2. Where a resident of Luxembourg Singapore derives income from Mexico or owns capital receives income in Singapore which, in accordance with the provisions of this Agreement, may be taxed in SingaporeMexico, Luxembourg Singapore shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (e), exempt such income or capital from tax. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 and 20 may be taxed in Singapore, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore. (c) For the purposes of sub-paragraph (b) of paragraph 1 the term "tax paid in Singapore" shall be deemed to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore its laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable paid in any country other than Singapore, Luxembourg allow the Mexican tax payablepaid, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against the Singapore tax payable in respect on the income of that incomeresident. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg Mexico to a company which is a resident of Singapore and which owns is a company owning directly at least 10 per cent or indirectly not less than 10% of the share capital in of the first-mentioned company, Singapore the deduction shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg Mexican tax paid by that company on the first-mentioned company in respect of that portion of the its profits out of which the dividend is paid. 3. For the purposes of paragraph 2 of this Article: (a) a tax of 15% shall be deemed to have been paid in Mexico in respect of dividends under Article 10 and royalties under Article 12; (b) the term "Mexican tax paid" shall be deemed to include, other than the tax mentioned in subparagraph (a), any amount which would have been payable as Mexican tax for any year but for a reduction of tax granted for that year on any part thereof as a result of the application of the following provisions of Mexican law: (i) Articles 10-B, 13, 51, 51-A, 77 (XVIII)and 143 of the Income Tax Law of Mexico so far as they were in force on, and have not been modified since, the date of signature of this Agreement, or have been modified only in minor respects so as not to affect their general character; or (ii) any other provisions which may subsequently be introduced, granting a 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. 1. In Luxembourg Singapore, double taxation shall be eliminated avoided as follows: (a) Where a resident of Luxembourg Singapore derives income or owns capital from Switzerland which, in accordance with the provisions of this Agreement, may be taxed in SingaporeSwitzerland, Luxembourg Singapore shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (e), exempt such income or capital from tax. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 and 20 may be taxed in Singapore, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore. (c) For the purposes of sub-paragraph (b) of paragraph 1 the term "tax paid in Singapore" shall be deemed to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore its laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg allow the Swiss tax payablepaid, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against the Singapore tax payable in respect on the income of that incomeresident. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg Switzerland to a company which is a resident of Singapore and which owns is a company owning directly at least or indirectly not less than 10 per cent of the share capital in of the first-mentioned company, Singapore the credit shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg Swiss tax paid by that company on the first-mentioned company in respect of that portion of the its profits out of which the dividend is paid. (b) Where a resident of Singapore derives income from Switzerland, Singapore shall, subject to the conditions of exemption for income received from outside Singapore provided for in the Singapore Income Tax Act being satisfied, exempt such income from tax in Singapore. 2. In Switzerland, double taxation shall be avoided as follows: (a) Where a resident of Switzerland derives income which, in accordance with the provisions of this Agreement, may be taxed in Singapore, Switzerland shall, subject to the provisions of subparagraph b), exempt such income from tax but may, in calculating tax on the remaining income of that resident, apply the rate of tax which would have been applicable if the exempted income had not been so exempted; provided, however, that such exemption shall apply to gains referred to in paragraph 4 of Article 13 only if actual taxation in Singapore is demonstrated. (b) Where a resident of Switzerland derives dividends, interest or royalties which, in accordance with the provisions of Articles 10, 11 and 12 may be taxed in Singapore, Switzerland shall allow, upon request, a relief to such resident. The relief may consist of: (i) a deduction from the tax on the income of that resident of an amount equal to the tax levied in Singapore in accordance with the provisions of Articles 10, 11 and 12; such deduction shall not, however, exceed that part of the Swiss tax, as computed before the deduction is given, which is appropriate to the income which may be taxed in Singapore; or (ii) a lump sum reduction of the Swiss tax; or (iii) a partial exemption of such dividends, interest or royalties from Swiss tax, in any case consisting at least of the deduction of the tax levied in Singapore from the gross amount of the dividends, interest and royalties. Switzerland shall determine the applicable relief and regulate the procedure in accordance with the Swiss provisions relating to the carrying out of international conventions of the Swiss Confederation for the avoidance of double taxation. (c) A company which is a resident of Switzerland and which derives dividends from a company which is a resident of Singapore shall be entitled, for the purposes of Swiss tax with respect to such dividends, to the same relief which would be granted to the company if the company paying the dividends were a resident of Switzerland.

ELIMINATION OF DOUBLE TAXATION. 1. In Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Luxembourg tax payable under the laws of Luxembourg and in accordance with this Agreement by a resident of Malaysia in respect of income derived from Luxembourg shall be allowed as a credit against Malaysian tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Malaysia and which owns not less than 10 per cent of the voting shares of the company paying the dividend, the credit shall take into account Luxembourg tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 2. Subject to the provision of the law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in SingaporeMalaysia, Luxembourg shall, subject to the provisions of sub-paragraphs subparagraphs (b), (c), ) to (d) and (e), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 12, 13, 18, and 20 23 may be taxed in SingaporeMalaysia, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in SingaporeMalaysia. 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 SingaporeMalaysia. (c) For Notwithstanding the purposes provisions of sub-paragraph (b) ), where a resident of paragraph 1 Luxembourg derives interest, royalties or technical fees in Malaysia, Luxembourg shall allow as a deduction from the term "tax paid in Singapore" shall be deemed on the income of that resident an amount equal to include the amount of Singapore tax which would have been payable but for the exemption or reduction of Malaysian tax provided under Singapore laws relating to incentives in accordance with special incentive measures for the promotion of economic development of industry, infrastructure, tourism and agriculture in Singapore. When applying to Malaysia, provided that in the followingcase of interest, the amount of royalties or technical fees, such tax shall be deemed to have been paid shall beat: (i) 10 per cent of the gross amount of dividends the interest referred to in the case of paragraph 1(b) of Article 1011; (ii) 10 8 per cent of the gross amount of interest the royalties referred to in the case of paragraph 2 of Article 11, and12; (iii) 10 8 per cent of the gross amount of royalties the fees for technical services referred to in Article 13. The provisions of this sub-paragraph shall apply for a period of ten years beginning on the 1 January in the case of paragraph 2 of Article 12calendar year following the year in which the Agreement enters into force. This period may be extended by mutual agreement between the competent authorities. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore Malaysian sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore Malaysia to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore Malaysian company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph sub-paragraph shall also apply notwithstanding that the Singapore Malaysian company is exempted from tax or taxed at a reduced rate in Singapore Malaysia in accordance with Singapore Malaysian laws providing incentives for the promotion of economic development of industry, infrastructure, tourism and agriculture in SingaporeMalaysia. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg tax payable, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Singapore and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paid.

ELIMINATION OF DOUBLE TAXATION. 1. In Panama double taxation will be eliminated as follows: a) Where a resident of Panama derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Luxembourg, Panama will exempt such income or capital from taxes. b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Panama is exempt from tax in Panama, Panama 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. Subject to the provisions of the law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle thereof, double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this AgreementConvention, may be taxed in SingaporePanama, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (ec), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 12, 14 and 20 17 may be taxed in SingaporePanama, Luxembourg shall allow as a deduction from the income tax on individuals or from the income corporation tax of that resident an amount equal to the tax paid in SingaporePanama. 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 SingaporePanama. (c) For the purposes The provisions of sub-paragraph (ba) of paragraph 1 the term "tax paid in Singapore" shall be deemed not apply to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is where Panama applies the provisions of this Convention to exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining such income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to applies the provisions of the laws paragraph 2 of Singapore regarding the allowance as a credit against Singapore tax Articles 10, 11 and 12, or of tax payable in any country other than Singapore, Luxembourg tax payable, whether directly or by deduction, in respect paragraph 1 of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable Article 14 to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Singapore and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paid.

ELIMINATION OF DOUBLE TAXATION. 1. In Luxembourg the case of Singapore, double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg Singapore derives income or owns capital from the Kingdom of Morocco which, in accordance with the provisions of this Agreement, may be taxed in Singaporethe Kingdom of Morocco, Luxembourg Singapore shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (e), exempt such income or capital from tax. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 and 20 may be taxed in Singapore, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore. (c) For the purposes of sub-paragraph (b) of paragraph 1 the term "tax paid in Singapore" shall be deemed to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore its laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg allow the Moroccan tax payablepaid, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against the Singapore tax payable in respect on the income of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of incomeresident. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg the Kingdom of Morocco to a company which is a resident of Singapore and which owns is a company owning directly at least or indirectly not less than 10 per cent of the share capital in of the first-first- mentioned company, Singapore the credit shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg Moroccan tax paid by that company on the first-mentioned company in respect of that portion of the its profits out of which the dividend is paid. 2. In the case of the Kingdom of Morocco, double taxation shall be eliminated as follows: (a) Where a resident of Morocco derives income which, in accordance with the provisions of this Agreement, may be taxed in Singapore, Morocco shall allow, subject to the provisions of paragraph 3, as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Singapore. However, such deduction shall not exceed that part of the Moroccan income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Singapore. (b) Where, in accordance with any provision of this Agreement, income derived by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the rate of tax on the remaining income of such resident, take into account the exempted income. 3. For the purposes of this Article, tax payable in a Contracting State shall include any amount which would have been payable but for an exemption or reduction of tax under the incentive laws of that Contracting State designed to promote economic development. The provisions of this paragraph shall only apply for the first 5 years for which this Agreement is effective.

ELIMINATION OF DOUBLE TAXATION. 1. In Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Luxembourg tax payable under the laws of Luxembourg and in accordance with this Agreement by a resident of Malaysia in respect of income derived from Luxembourg shall be allowed as a credit against Malaysian tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Malaysia and which owns not less than 10 per cent of the voting shares of the company paying the dividend, the credit shall take into account Luxembourg tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 2. Subject to the provisions of the law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in SingaporeMalaysia, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), () to d) and (e), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 12, 13, 18, and 20 23 may be taxed in SingaporeMalaysia, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in SingaporeMalaysia. 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 SingaporeMalaysia. (c) For Notwithstanding the purposes provisions of sub-paragraph (b) ), where a resident of paragraph 1 Luxembourg derives interest, royalties or technical fees in Malaysia, Luxembourg shall allow as a deduction from the term "tax paid in Singapore" shall be deemed on the income of that resident an amount equal to include the amount of Singapore tax which would have been payable but for the exemption or reduction of Malaysian tax provided under Singapore laws relating to incentives in accordance with special incentive measures for the promotion of economic development of industry, infrastructure, tourism and agriculture in Singapore. When applying to Malaysia, provided that in the followingcase of interest, the amount of royalties or technical fees, such tax shall be deemed to have been paid shall beat: (i) 10 per cent of the gross amount of dividends the interest referred to in the case of paragraph 1(b) of Article 1011; (ii) 10 8 per cent of the gross amount of interest the royalties referred to in the case of paragraph 2 of Article 11, and12; (iii) 10 8 per cent of the gross amount of royalties the fees for technical services referred to in the case of paragraph 2 of Article 1213. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore Malaysian sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore Malaysia to an income tax corresponding to the Luxembourg corporation tax. The abovementioned above-mentioned shares in the Singapore Malaysian company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph sub-paragraph shall also apply notwithstanding that the Singapore Malaysian company is exempted from tax or taxed at a reduced rate in Singapore Malaysia in accordance with Singapore Malaysian laws providing incentives for the promotion of economic development of industry, infrastructure, tourism and agriculture in SingaporeMalaysia. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg tax payable, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Singapore and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paid.

ELIMINATION OF DOUBLE TAXATION. 1. 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 Luxembourg, 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 Luxembourg; (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid thereon in Luxembourg. Such deduction in either case shall not, however, exceed that part of the income tax 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 which may be taxed in Luxembourg. b) For the purposes of sub-paragraph a), where a company that is a resident of Lithuania receives a dividend from a company that is a resident of Luxembourg in which it owns at least 10 per cent of its shares having full voting rights, the tax paid in Luxembourg shall include not only the tax paid on the dividend, but also the tax paid on the underlying profits of the company out of which the dividend was paid. 2. Subject to the provisions of the law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this AgreementConvention, may be taxed in SingaporeLithuania, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (ec), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 12, 17 and 20 22 may be taxed in SingaporeLithuania, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in SingaporeLithuania. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable attributable, to such items of income derived from SingaporeLithuania. (c) For the purposes The provisions of sub-paragraph (ba) of paragraph 1 the term "tax paid in Singapore" shall be deemed not apply to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is where Lithuania applies the provisions of this Convention to exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining such income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to applies the provisions of the laws paragraph 2 of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than SingaporeArticles 10, Luxembourg tax payable, whether directly 11 or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable 12 to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Singapore and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paid.

ELIMINATION OF DOUBLE TAXATION. 1. In Luxembourg the Sultanate of Oman, double taxation shall be eliminated as follows: (a) Where a resident of the Sultanate of Oman derives income, or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Luxembourg, the Sultanate of Oman shall allow as a deduction from the tax on the income or capital of that resident an amount equal to the income or capital tax paid in Luxembourg, whether directly or by deduction. Such deduction shall not, however, exceed that part of the income or capital tax (as computed before the deduction is given) which is attributable to the income or capital which may be taxed in Luxembourg. b) Where, in accordance with any provision of this Agreement, income derived or capital owned by a resident of the Sultanate of Oman is exempt from tax in the Sultanate of Oman, the Sultanate of Oman 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. Subject to the provisions of the Luxembourg law regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be eliminated as follows: a) where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Singaporethe Sultanate of Oman, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (ed), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted. (b) Where where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8Article 7, Article 10, 11Article 12, 12 paragraph 2 of Article 13 and 20 Article 17 may be taxed in Singaporethe Sultanate of Oman, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Singaporethe Sultanate of Oman, but only, with respect to Article 7 and paragraph 2 of Article 13, if the business profits and the capital gains are not derived from activities in agriculture, industry, infrastructure and tourism in the Sultanate of Oman. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore.the Sultanate of Oman; (c) For the purposes of sub-paragraph (b) of paragraph 1 the term "tax paid in Singapore" shall be deemed to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where where a company which is a resident of Luxembourg derives dividends from Singapore Omani sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 ten per cent (10%) of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore the Sultanate of Oman to an income tax corresponding to the Luxembourg corporation tax. The abovementioned above-mentioned shares in the Singapore Omani company are, under the same conditions, exempt from the Luxembourg capital tax. The This exemption under this subparagraph sub-paragraph shall also apply notwithstanding that the Singapore Omani company is exempted from tax or taxed at a reduced rate in Singapore the Sultanate of Oman and if these dividends are derived out of profits from activities in accordance with Singapore laws providing incentives for agriculture, industry, infrastructure or tourism in the promotion Sultanate of economic development in Singapore.Oman; 2. In Singapore, double taxation shall be eliminated as follows: (ad) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg tax payable, whether directly sub-paragraph a) shall not apply to income derived or capital owned by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg where the Sultanate of Oman applies the provisions of this Agreement to a company which is a resident exempt such income or capital from tax or applies the provisions of Singapore paragraph 2 of Articles 10 and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition 12 to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paidsuch income.

ELIMINATION OF DOUBLE TAXATION. 1. In Singapore, double taxation shall be avoided as follows: Where a resident of Singapore derives income from Luxembourg which, in accordance with the provisions of this Agreement, may be taxed in Luxembourg, Singapore shall, subject to its laws regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, allow the Luxembourg tax paid, whether directly or by deduction, as a credit against the Singapore tax payable on the income of that resident. Where such income is a dividend paid by a company which is a resident of Luxembourg to a resident of Singapore which is a company owning directly or indirectly not less than 10 per cent of the share capital of the first-mentioned company, the credit shall take into account the Luxembourg tax paid by that company on the portion of its profits out of which the dividend is paid. 2. In Luxembourg, double taxation shall be avoided as follows: Subject to the provisions of the law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Singapore, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (ed), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8Article 12, 10, 11, 12 Article 17 and 20 paragraph 3 of Article 21 may be taxed in Singapore, Luxembourg shall allow as a deduction from the income tax on individuals or from the income corporation tax of that resident an amount equal to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore. (c) For the purposes The provisions of sub-paragraph (ba) of paragraph 1 the term "tax paid in Singapore" shall be deemed not apply to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is where Singapore applies the provisions of this Agreement to exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining such income or capital from tax or applies the provisions of paragraph 2 of Article 12 to such resident, take into account the exempted income or capitalincome. (ed) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph sub-paragraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg tax payable, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Singapore and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paid.

ELIMINATION OF DOUBLE TAXATION. 1. In Luxembourg double taxation shall be eliminated as follows: (a) Where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Singapore, Luxembourg shall, subject to the provisions of sub-paragraphs (b), (c), (d) and (e), exempt such income or capital from tax. (b) Where a resident of Luxembourg derives items of income which, in accordance with the provisions of Articles 8, 10, 11, 12 and 20 may be taxed in Singapore, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Singapore. (c) For the purposes of sub-paragraph (b) of paragraph 1 1) the term "“tax paid in Singapore" ” shall be deemed to include the amount of Singapore tax which would have been payable but for the exemption or reduction of tax provided under Singapore laws relating to incentives for the promotion of economic development in Singapore. When applying to the following, the amount of tax deemed to have been paid shall be: (i) 10 per cent of the gross amount of dividends in the case of paragraph 1(b1 b) of Article 10; (ii) 10 per cent of the gross amount of interest in the case of paragraph 2 of Article 11, and (iii) 10 per cent of the gross amount of royalties in the case of paragraph 2 of Article 12. (d) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Luxembourg is exempt from tax in Luxembourg, Luxembourg may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. (e) Where a company which is a resident of Luxembourg derives dividends from Singapore sources, Luxembourg shall exempt such dividends from tax, provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject in Singapore to an income tax corresponding to the Luxembourg corporation tax. The abovementioned above-mentioned shares in the Singapore company are, under the same conditions, exempt from the Luxembourg capital tax. The exemption under this subparagraph sub-paragraph shall also apply notwithstanding that the Singapore company is exempted from tax or taxed at a reduced rate in Singapore in accordance with Singapore laws providing incentives for the promotion of economic development in Singapore. 2. In Singapore, double taxation shall be eliminated as follows: (a) Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, Luxembourg tax payable, whether directly or by deduction, in respect of income from sources within Luxembourg shall be allowed as a credit against Singapore tax payable in respect of that income. The credit shall not, however, exceed that part of the Singapore tax, as computed before the credit is given, which is attributable to such item of income. (b) Where such income is a dividend paid by a company which is a resident of Luxembourg to a company which is a resident of Singapore and which owns directly at least 10 per cent of the capital in the first-mentioned company, Singapore shall take into account (in addition to any Luxembourg tax on the dividend) the Luxembourg tax paid by the first-mentioned company in respect of that portion of the profits out of which the dividend is paid.tax