Common use of ELIMINATION OF DOUBLE TAXATION Clause in Contracts

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan regarding the allowance as a credit against Kazakhstan tax of tax payable in any country other than Kazakhstan, the Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia shall be allowed as a credit against Kazakhstan tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and the special incentives under the Malaysian laws for the promotion of economic development of Malaysia which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Kazakhstan tax payable" shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to In the laws case of Kazakhstan regarding the allowance as a credit against Kazakhstan tax of Thailand : (a) Philippine tax payable in any country other than Kazakhstan, the Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia the Philippines shall be allowed as a credit against Kazakhstan Thai tax payable in respect of that income. ; (b) Where such income is a dividend paid by a company which is a resident of the Philippines to a company which is a resident of Thailand and which owns not less than 15 per cent of votingshares of the company paying the dividend, the credit shall take into account the Philippine tax payable by that company in respect of its income, and (c) The credit shall not, however, exceed that part of the Kazakhstan Thai tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the The term "Malaysian Philippine tax payable" shall be deemed to include Malaysian the amount of Philippine tax which would, under would have been paid if the laws of Malaysia and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and Convention and/or the special incentives under the Malaysian incentive laws for the promotion of designed to promote economic development of Malaysia which were in force the Philippines, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Malaysia the future in the Philippine taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws. 3. In the case of the Philippines : Subject to the laws of Malaysia the Philippines regarding the allowance as a credit against Malaysian Philippine tax of tax payable in any country other than Malaysia, the Kazakhstan Philippines, (a) Thai tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan Thailand shall be allowed as a credit against Malaysian the Philippine tax payable in respect of that income. ; (b) Where such income is a dividend paid by a company which is a resident of Thailand to a company which is a resident of the Philippines and which owns not less that 15 per cent of voting shares of the company paying the dividend, the credit shall take into account the Thai tax payable by that company in respect of its income; and (c) The credit shall not, however, exceed that part of the Malaysian tax, Philippine tax as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the The term "Kazakhstan Thai tax payable" shall be deemed to include Kazakhstan the amount of Thai tax which would, under would have been paid if the laws of Kazakhstan and Thai tax had not been reduced in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and Convention and/or the special incentives under the Kazakhstan incentive laws for the promotion of designed to promote economic development of Kazakhstan which were in force Thailand, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Kazakhstan the future in the Thai taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan regarding the allowance as a credit against Kazakhstan tax of tax payable in any country other than Kazakhstan, the Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia shall be allowed as a credit against Kazakhstan tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and the special incentives under the Malaysian laws for the promotion of economic development of Malaysia which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan Philippine tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan the Philippines 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 the Philippines to a company which is a resident of Malaysia and which owns not less than 15 per cent of the voting shares of the company paying the dividend, the credit shall take into account Philippine 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. 42. For the purposes of paragraph 31, the term "Kazakhstan Philippine tax payable" shall be deemed to include Kazakhstan the amount of Philippine tax which would, under would have been paid if the laws of Kazakhstan and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and and (a) the special incentives under the Kazakhstan incentive laws for the promotion of designed to promote economic development of Kazakhstan which were in the Philippines so far as they are in force on the date of signature of this Agreement or Agreement; or (b) any other provisions which may subsequently be introduced in Kazakhstan the Philippines in modification of, or in addition to, those the existing special incentive laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of the Philippines regarding the allowance as a credit against Philippine tax of tax payable in any country other than the Philippines, Malaysian tax payable in respect of income derived from Malaysia shall be allowed as a credit against the Philippine tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Malaysia to a company which is a resident of the Philippines and which owns not less than 15 per cent of the voting shares of the company paying the dividend, the credit shall take in to account Malaysian tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Philippine tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on: (a) any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with: (i) sections 54A and 60A and Schedule 7A of the Income Tax Act, 1967 of Malaysia; or (ii) sections 21, 22, 26 and 30Q of the Investment Xxxxxxxxxx Xxx, 0000 xx Xxxxxxxx; so far as they were in force on the date of signature of this Agreement; and (iii) any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, the investment incentives laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character; (b) interest to which paragraph 3 of Article 11 applies had that interest not been exempted from Malaysian tax in accordance with that paragraph; and (c) approved industrial royalties to which paragraph 2(a)(ii) of Article 12 applies had those royalties not been exempted from Malaysian tax in accordance with that paragraph. 5. For the purposes of paragraph 3, where royalties derived by a resident of the Philippines are, as film rentals, subject to cinematograph film hire duty in Malaysia, that duty shall be deemed to be Malaysian tax.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan Malaysia regarding the allowance as a credit against Kazakhstan Malaysian tax of tax payable in any country other than KazakhstanMalaysia, the Malaysian Indonesian tax payable under the laws of Malaysia Indonesia and in accordance with this Agreement by a resident of Kazakhstan Malaysia in respect of income derived from Malaysia Indonesia shall be allowed as a credit against Kazakhstan Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Indonesian tax payable" shall be deemed to include the amount of Indonesian tax which would have been paid if the Indonesian tax had not been exempted or reduced in accordance with this Agreement and: (a) the special incentive laws designed to promote economic development in Indonesia so far as they are in force on the date of signature of this Agreement; or (b) any other provisions which may subsequently be introduced in Indonesia in modification of, or in addition to, the existing special incentive laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Indonesia regarding the allowance as a credit against Indonesian tax of tax payable in any country other than Indonesia, Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Indonesia in respect of income derived from Malaysia shall be allowed as a credit against the Indonesian tax payable in respect of that income. The credit shall not, however, exceed that part of the Indonesian tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and with: (a) the special incentives under the Malaysian incentive laws for the promotion of economic development of Malaysia which so far as they were in force on 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; and (b) any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those the investment incentives laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 45. For the purposes of paragraph 3, royalties derived by a resident of Indonesia from film rentals, which are subjected to duty under the term "Kazakhstan tax payable" Cinematograph Film-Hire Duty Act in Malaysia, that duty shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterMalaysian tax.

ELIMINATION OF DOUBLE TAXATION. 1. Subject The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except where provisions to the laws contrary are made in this Convention. 2. The amount of Kazakhstan regarding the allowance as a credit against Kazakhstan Philippine tax of tax payable in any country other than Kazakhstanpayable, the Malaysian tax payable under the laws of Malaysia the Philippines and in accordance with the provisions of this Agreement Convention, whether directly or by deduction, by a resident of Kazakhstan India, in respect of profits or income derived from Malaysia arising in the Philippines, which have been subjected to tax both in India and in the Philippines, shall be allowed as a credit against Kazakhstan the Indian tax payable in respect of such profits or income provided that income. The such credit shall not, however, not exceed that part of the Kazakhstan tax, Indian tax (as computed before the credit is given, allowing any such credit) which is appropriate to the profits or income arising in the Philippines. Further, where such item of resident is a company by which surtax is payable in India, the credit aforesaid shall be allowed in the first instance against income-tax payable by the company in India and as to the balance, if any, against surtax payable by it in India. 23. For the purposes of paragraph 1, the The term "Malaysian “Philippine tax payable" ” shall be deemed to include Malaysian the amount of Philippine tax which would, under would have been paid if the laws of Malaysia and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement Convention and the special incentives under the Malaysian incentive laws for the promotion of designed to promote economic development of Malaysia which were in force the Philippines, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Malaysia the future in the Philippine taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws. 34. Subject to the laws The amount of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan Indian tax payable under the laws of Kazakhstan India and in accordance with the provisions of this agreement Convention, whether directly or by deduction, by a resident of Malaysia the Philippines, in respect of profits or income derived from Kazakhstan arising in India, which has been subjected to tax both in India and the Philippines, shall be allowed as a credit against Malaysian Philippine tax payable in respect of such profits or income provided that income. The such credit shall not, however, not exceed that part of the Malaysian tax, Philippine tax (as computed before the credit is given, allowing any such credit) which is appropriate to such item of incomethe profits or income arising in India. 45. For the purposes of the credit referred to in paragraph 34, the term "Kazakhstan “Indian tax payable" ” shall be deemed to include Kazakhstan tax any amount which would, under the laws of Kazakhstan and in accordance with this Agreement, would have been payable on as Indian tax for any income derived from sources in Kazakhstan had assessment year but for an exemption or reduction of tax granted for that year or any part thereof by the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with special incentive measures under the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion Income-tax Act, 1961 (43 of 1961), which are designed to promote economic development of Kazakhstan which were in force on the date of signature of this Agreement development, or any other provisions which may subsequently be introduced in Kazakhstan hereafter in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting provisions for promoting economic development in India.

ELIMINATION OF DOUBLE TAXATION. 1. Subject The laws of each of the Contracting States shall continue to govern the taxation of income whether derived from the Contracting State or elsewhere except where express provisions to the laws contrary are made in this Agreement. Where income derived from a Contracting State is subject to tax in both Contracting States, relief from double taxation on such income shall be given in accordance with the following provisions of Kazakhstan regarding this Article. 2. In the allowance case of Indonesia, double taxation shall be avoided as follows : (a) Indonesia, when imposing tax on residents of Indonesia, may include in the basis upon which such tax is imposed, the items of income which may be taxed in the Philippines in accordance with the provisions of this Agreement. (b) Where a resident of Indonesia derives income from the Philippines and that income may be taxed in the Philippines in accordance with the provisions of this Agreement, the amount of Philippine tax payable in respect of that income shall be allowed as a credit against Kazakhstan 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 that income. 3. In the case of the Philippines, double taxation shall be avoided as follows : Subject to the provisions of the laws of the Philippines relating to the allowance as credit against Philippine tax of tax payable in any country other than Kazakhstanthe Philippines, the Malaysian tax payable Indonesian taxes paid or accrued under the laws of Malaysia Indonesia and in accordance with this Agreement Agreement, whether directly or by a resident of Kazakhstan deduction, in respect of income derived from Malaysia sources within Indonesia shall be allowed as a credit against Kazakhstan Philippine tax payable in respect of that income. 4. The credit shall not, however, exceed that part Taxes which have been exempted or reduced in one of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions Contracting States by virtue of this Agreement and or the special incentives under the Malaysian incentive laws for the promotion of that Contracting State designed to promote economic development of Malaysia which were in force development, effective on the date of signature of this Agreement Agreement, or any other provisions which may subsequently be introduced in Malaysia future taxation laws in modification of, or in addition to, those laws so far the existing laws, shall be considered as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan though such taxes had been paid and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a tax credit against Malaysian in the other Contracting State in an amount equal to the tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is would have been appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Kazakhstan tax payable" shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not concerned if no such exemption had been taxed at a reduced rate given or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterno such reduction had been allowed.

ELIMINATION OF DOUBLE TAXATION. 1. The laws of each of the Contracting States shall continue to govern the taxation of income whether derived from the Contracting State or elsewhere except where express provisions to the contrary are made in this Agreement. Where income derived from a Contracting State is subject to tax in both Contracting States, relief from double taxation on such income shall be given in accordance with the following provisions of this Article. 2. In the case of the Philippines, double taxation shall be avoided as follows: Subject to the provisions of the laws of Kazakhstan regarding the Philippines relating to the allowance as a credit against Kazakhstan Philippine tax of tax payable in any country other than Kazakhstanthe Philippines, the Malaysian tax payable Indonesian taxes paid or accrued under the laws of Malaysia Indonesia and in accordance with this Agreement Agreement, whether directly or by a resident of Kazakhstan deduction, in respect of income derived from Malaysia sources within Indonesia shall be allowed as a credit against Kazakhstan Philippine tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income. 23. For In the purposes case of paragraph 1Indonesia, double taxation shall be avoided as follows: a) Indonesia, when imposing tax on residents of Indonesia, may include in the basis upon which such tax is imposed, the term "Malaysian tax payable" shall items of income which may be deemed to include Malaysian tax which would, under taxed in the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax Philippines in accordance with the provisions of this Agreement. b) Where a resident of Indonesia derives income from the Philippines and that income may be taxed in the Philippines in accordance with the provisions of this Agreement, the amount of Philippine tax payable in respect of that 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 that income. 4. Taxes which have been exempted or reduced in one of the Contracting States by virtue of this Agreement and or the special incentives under the Malaysian incentive laws for the promotion of that Contracting State designed to promote economic development of Malaysia which were in force development, effective on the date of signature of this Agreement Agreement, or any other provisions which may subsequently be introduced in Malaysia future taxation laws in modification of, or in addition to, those laws so far the existing laws, shall be considered as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan though such taxes had been paid and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a tax credit against Malaysian in the other Contracting State in an amount equal to the tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is would have been appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Kazakhstan tax payable" shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not concerned if no such exemption had been taxed at a reduced rate given or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterno such reduction had been allowed.

ELIMINATION OF DOUBLE TAXATION. 1. Subject In the Philippines, in accordance with the provisions and subject to the limitations of the laws of Kazakhstan regarding the allowance Philippines, as a credit against Kazakhstan tax may be amended from time to time without changing the general principle hereof, double taxation shall be eliminated as follows: In accordance with the principles of tax payable in any country other than Kazakhstanthis Convention, the Malaysian tax payable taxes paid or accrued under the laws of Malaysia and in accordance with this Agreement Denmark whether directly or by a resident of Kazakhstan deduction, in respect of income derived from Malaysia sources within Denmark shall be allowed as a credit against Kazakhstan Philippine tax payable subject to the following limitations: (i) the amount of the credit in respect to the tax paid or accrued to Denmark shall not exceed the same proportion of that incomethe taxes covered by the Convention against which such credit is taken, which the taxpayer’s taxable income from sources within Denmark bears to his entire taxable income for the same taxable year; and (ii) the total amount of the credit shall not exceed the same proportion of the taxes covered by the Convention against which such credit is taken, which the taxpayer’s taxable income from sources outside the Philippines bears to his entire taxable income for the same taxable year. In the case of a Philippine corporation owning directly or indirectly more than 50 per cent of the voting stock of a Danish company from which it receives dividends in any taxable year, the Philippines shall also allow credit for the appropriate amount of taxes paid or accrued to Denmark by a Danish company paying such dividends with respect to such profits out of which such dividends are paid. The credit deduction shall not, however, exceed that part of the Kazakhstan Philippine income tax, as computed before the credit deduction is given, which is appropriate to such item of incomethe income which may be taxed in Denmark. 2. For In Denmark, in accordance with the purposes provisions and subject to the limitations of paragraph 1, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this AgreementDenmark, have been payable on any as may be amended from time to time without changing the general principle hereof, double taxation shall be eliminated as follows: a) Subject to the provisions of sub-paragraph (c), where a resident of Denmark derives income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax which, in accordance with the provisions of this Agreement and Convention, may be taxed in the special incentives under Philippines, Denmark shall allow as a deduction from the Malaysian laws for the promotion of economic development of Malaysia which were in force tax on the date income of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification ofthat resident, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject an amount equal to the laws of Malaysia regarding income tax paid in the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit Philippines; b) such deduction shall not, however, exceed that part of the Malaysian income tax, as computed before the credit deduction is given, which is appropriate attributable to such item the income which may be taxed in the Philippines; c) where a resident of income. 4. For the purposes of paragraph 3Denmark derives income which, the term "Kazakhstan tax payable" shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with the provisions of this AgreementConvention shall be taxable only in the Philippines, have been payable on any Denmark 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 attributable to the income derived from sources in Kazakhstan had the income Philippines; d) if dividends paid by a company which is a resident of the Philippines to a company which is a resident of Denmark and which owns at least 25 per cent of the capital of the company paying the dividends, are not been taxed at a reduced rate or exempted exempt from Kazakhstan Danish tax in accordance with the provisions of this Agreement and Danish law governing the special incentives under exemption of tax on dividends, the Kazakhstan laws credit for the promotion purposes of economic development of Kazakhstan which were in force on sub-paragraphs (a) and (b) shall take into account the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed Philippine tax payable by the competent authorities company paying the dividends in respect of the Contracting States to be profits out of a substantially similar characterwhich such dividends are paid.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan regarding the allowance as a credit against Kazakhstan tax of tax payable in any country other than Kazakhstan, the Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia shall be allowed as a credit against Kazakhstan tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and the special incentives under the Malaysian laws for the promotion of economic development of Malaysia which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan Philippine tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan the Philippines 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 the Philippines to a company which is a resident of Malaysia and which owns not less than 15 per cent of the voting shares of the company paying dividend, the credit shall take into account Philippine 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. 42. For the purposes of paragraph 31, the term "Kazakhstan “Philippine tax payable" ” shall be deemed to include Kazakhstan the amount of Philippine tax which would, under would have been paid if the laws of Kazakhstan and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and and: a) the special incentives under the Kazakhstan incentive laws for the promotion of designed to promote economic development of Kazakhstan which were in the Philippines so far as they are in force on the date of signature of this Agreement or Agreement; or b) any other provisions which may subsequently be introduced in Kazakhstan the Philippines in modification of, or in addition to, those the existing special incentive laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of the Philippines regarding the allowance as a credit against Philippine tax of tax payable in any country other than the Philippines, Malaysian tax payable in respect of income derived from Malaysia shall be allowed as a credit against the Philippine tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Malaysia to a company which is a resident of the Philippines and which owns not less than 15 per cent of the voting shares of the company paying the dividend, the credit shall take into account Malaysian tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Philippine tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term “Malaysian tax payable” shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on: a) any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with: (i) sections 54A and 60A and Schedule 7A of the Income Tax Act, 1967 of Malaysia; or (ii) sections 21, 22, 26 and 300 of the Investment Incentives Act, 1968 of Malaysia; so far as they were in force on the date of signature of this Agreement; and (iii) any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, the investment incentives laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character; b) interest to which paragraph 3 of Article 11 applies had that interest not been exempted from Malaysian tax in accordance with that paragraph; and c) approved industrial royalties to which paragraph 2(a)(ii) of Article 12 applies had those royalties not been exempted from Malaysian tax in accordance with that paragraph. 5. For the purposes of paragraph 3, where royalties derived by a resident of the Philippines are, as film rentals, subject to cinematograph film-hire duty in Malaysia, that duty shall be deemed to be Malaysian tax.

ELIMINATION OF DOUBLE TAXATION. 1. In the case of the Philippines: Subject to the laws law of Kazakhstan the Philippines regarding the allowance as a credit against Kazakhstan Philippine tax of tax payable in any country other than Kazakhstan, the Malaysian Philippines, a) Thai tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia Thailand shall be allowed as a credit against Kazakhstan the Philippine tax payable in respect of that income. ; b) Where such income is a dividend paid by a company which is a resident of Thailand to a company which is a resident of the Philippines and which owns not less than 15 per cent of voting shares of the company paying the dividend, the credit shall take into account the Thai tax payable by that company in respect of its income; and c) The credit shall not, however, exceed that part of the Kazakhstan Philippine tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the The term "Malaysian “Thai tax payable" ” shall be deemed to include Malaysian the amount of Thai tax which would, under would have been paid if the laws of Malaysia and Thai tax had not been reduced in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and Convention and/or the special incentives under the Malaysian incentive laws for the promotion of designed to promote economic development of Malaysia which were in force Thailand, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Malaysia the future in the Thai taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws. 3. Subject to In the laws case of Malaysia regarding the allowance as a credit against Malaysian tax of Thailand: a) Philippine tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan the Philippines shall be allowed as a credit against Malaysian Thai tax payable in respect of to that income. ; b) Where such income is a dividend paid by a company which is a resident of the Philippines to a company which is a resident of Thailand and which owns not less than 15 per cent of voting shares of the company paying the dividend, the credit shall take into account the Philippine tax payable by that company in respect of its income; and c) The credit shall not, however, exceed that part of the Malaysian Thai tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the The term "Kazakhstan “Philippine tax payable" ” shall be deemed to include Kazakhstan the amount of Philippine tax which would, under would have been paid if the laws of Kazakhstan and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the Convention and/or special incentives under the Kazakhstan incentive laws for the promotion of designed to promote economic development of Kazakhstan which were in force the Philippines, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Kazakhstan the future in the Philippine taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws.

ELIMINATION OF DOUBLE TAXATION. 1. Subject The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except where provisions to the laws contrary are made in this Convention. 2. The amount of Kazakhstan regarding the allowance as a credit against Kazakhstan Philippine tax of tax payable in any country other than Kazakhstanpayable, the Malaysian tax payable under the laws of Malaysia the Philippines and in accordance with the provisions of this Agreement Convention, whether directly or by deduction, by a resident of Kazakhstan India, in respect of profits or income derived from Malaysia arising in the Philippines, which have been subjected to tax both in India and in the Philippines, shall be allowed as a credit against Kazakhstan the Indian tax payable in respect of such profits or income provided that income. The such credit shall not, however, not exceed that part of the Kazakhstan tax, Indian tax (as computed before the credit is given, allowing any such credit) which is appropriate to the profits or income arising in the Philippines. Further, where such item of incomeresident is a company by which surtax is payable in India, the credit aforesaid shall be allowed in the first instance against income tax payable by the company in India and as to the balance, if any, against surtax payable by it in India. 23. For the purposes of paragraph 1, the The term "Malaysian “Philippine tax payable" ” shall be deemed to include Malaysian the amount of Philippine tax which would, under would have been paid if the laws of Malaysia and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement Convention and the special incentives under the Malaysian incentive laws for the promotion of designed to promote economic development of Malaysia which were in force the Philippines, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Malaysia the future in the Philippine taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws. 34. Subject to the laws The amount of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan Indian tax payable under the laws of Kazakhstan India and in accordance with the provisions of this agreement Convention, whether directly or by deduction, by a resident of Malaysia the Philippines, in respect of profits or income derived from Kazakhstan arising in India, which has been subjected to tax both in India and the Philippines, shall be allowed as a credit against Malaysian Philippine tax payable in respect of such profits or income provided that income. The such credit shall not, however, not exceed that part of the Malaysian tax, Philippine tax (as computed before the credit is given, allowing any such credit) which is appropriate to such item of incomethe profits or income arising in India. 45. For the purposes of the credit referred to in paragraph 34, the term "Kazakhstan “Indian tax payable" ” shall be deemed to include Kazakhstan tax any amount which would, under the laws of Kazakhstan and in accordance with this Agreement, would have been payable on as Indian tax for any income derived from sources in Kazakhstan had assessment year but for an exemption or reduction of tax granted for that year or any part thereof by the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with special incentive measures under the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion Income Tax Act, 1961 (43 of 1961), which are designed to promote economic development of Kazakhstan which were in force on the date of signature of this Agreement development, or any other provisions which may subsequently be introduced in Kazakhstan hereafter in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting provisions for promoting economic development in India.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan Malaysia regarding the allowance as a credit against Kazakhstan Malaysian tax of tax payable in any country other than KazakhstanMalaysia, the Malaysian Indonesian tax payable under the laws of Malaysia Indonesia and in accordance with this Agreement by a resident of Kazakhstan Malaysia in respect of income derived from Malaysia Indonesia shall be allowed as a credit against Kazakhstan Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Indonesian tax payable" shall be deemed to include the amount of Indonesian tax which would have been paid if the Indonesian tax had not been exempted or reduced in accordance with this Agreement and: the special incentive laws designed to promote economic development (a) in Indonesia so far as they are in force on the date of signature of this Agreement; or (b) any other provisions which may subsequently be introduced in Indonesia in modification of, or in addition to, the existing special incentive laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Indonesia regarding the allowance as a credit against Indonesian tax of tax payable in any country other than Indonesia, Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Indonesia in respect of income derived from Malaysia shall be allowed as a credit against the Indonesian tax payable in respect of that income. The credit shall not, however, exceed that part of the Indonesian tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and with: (a) the special incentives under the Malaysian incentive laws for the promotion of economic development of Malaysia which so far as they were in force on 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; and (b) any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those the investment incentives laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 45. For the purposes of paragraph 3, royalties derived by a resident of Indonesia from film rentals, which are subjected to duty under the term "Kazakhstan tax payable" Cinematograph Film-Hire Act in Malaysia, that duty shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterMalaysian tax.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan Singapore regarding the allowance as a credit against Kazakhstan Singapore tax of tax payable in any country other than KazakhstanSingapore, the Malaysian Philippine tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia the Philippines shall be allowed as a credit against Kazakhstan Singapore tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of the Philippines to a company which is a resident of Singapore and which owns not less than 15 per cent of voting shares of the company paying the dividend, the credit shall take into account the Philippine tax payable by that company in respect of its income. The credit shall not, however, exceed that part of the Kazakhstan Singapore tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the The term "Malaysian “Philippine tax payable" ” shall be deemed to include Malaysian the amount of Philippine tax which would, under would have been paid if the laws of Malaysia and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement Convention and the special incentives under the Malaysian incentive laws for the promotion of designed to promote economic development of Malaysia which were in force the Philippines, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Malaysia the future in the Philippine taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws. 3. Subject to the laws of Malaysia the Philippines regarding the allowance as a credit against Malaysian Philippine tax of tax payable in any country other than Malaysiathe Philippines, the Kazakhstan Singapore tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan Singapore shall be allowed as a credit against Malaysian the Philippine tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Singapore to a company which is a resident of the Philippines and which owns not less than 15 per cent of the voting shares of the company paying the dividend, the credit shall take into account the Singapore tax payable by that company in respect of its income. The credit shall not, however, exceed that part of the Malaysian Philippine tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the The term "Kazakhstan “Singapore tax payable" ” shall be deemed to include Kazakhstan the amount of Singapore tax which would, under would have been paid if the laws of Kazakhstan and Singapore tax had not been reduced in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement Convention and the special incentives under the Kazakhstan incentive laws for the promotion of designed to promote economic development of Kazakhstan which were in force Singapore, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Kazakhstan the future in the Singapore taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan regarding the allowance as a credit against Kazakhstan tax of tax payable in any country other than Kazakhstan, the Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia shall be allowed as a credit against Kazakhstan tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "«Malaysian tax payable" » shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and the special incentives under the Malaysian laws for the promotion of economic development of Malaysia which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "«Kazakhstan tax payable" » shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan Malaysia regarding the allowance as a credit against Kazakhstan Malaysian tax of tax payable in any country other than KazakhstanMalaysia, the Malaysian Indonesian tax payable under the laws of Malaysia Indonesia and in accordance with this Agreement by a resident of Kazakhstan Malaysia in respect of income derived from Malaysia Indonesia shall be allowed as a credit against Kazakhstan Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Indonesian tax payable" shall be deemed to include the amount of Indonesian tax which would have been paid if the Indonesian tax had not been exempted or reduced in accordance with this Agreement and: (a) the special incentive laws designed to promote economic development in Indonesia so far as they are in force on the date of signature of this Agreement; or (b) any other provisions which may subsequently be introduced in Indonesia in modification of, or in addition to, the existing special incentive laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Indonesia regarding the allowance as a credit against Indonesian tax of tax payable in any country other than Indonesia, Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Indonesia in respect of income derived from Malaysia shall be allowed as a credit against the Indonesian tax payable in respect of that income. The credit shall not, however, exceed that part of the Indonesian tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and with: (a) the special incentives under the Malaysian incentive laws for the promotion of economic development of Malaysia which so far as they were in force on 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; and (b) any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those the investment incentives laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 45. For the purposes of paragraph 3, royalties derived by a resident of Indonesia from film rentals, which are subjected to duty under the term "Kazakhstan tax payable" Cinematograph Film-Hire Act in Malaysia, that duty shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterMalaysian tax.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the laws of Kazakhstan regarding the allowance as a credit against Kazakhstan tax of tax payable in any country other than Kazakhstan, the Malaysian tax payable under the laws of Malaysia and in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia shall be allowed as a credit against Kazakhstan tax payable in respect of that income. The credit shall not, however, exceed that part of the Kazakhstan tax, as computed before the credit is given, which is appropriate to such item of income. 2. For the purposes of paragraph 1, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement and the special incentives under the Malaysian laws for the promotion of economic development of Malaysia which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan Philippine tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan the Philippines 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 the Philippines to a company which is a resident of Malaysia and which owns not less than 15 per cent of the voting shares of the company paying the dividend, the credit shall take into account Philippine 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. 42. For the purposes of paragraph 31, the term "Kazakhstan Philippine tax payable" shall be deemed to include Kazakhstan the amount of Philippine tax which would, under would have been paid if the laws of Kazakhstan and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and and (a) the special incentives under the Kazakhstan incentive laws for the promotion of designed to promote economic development of Kazakhstan which were in the Philippines so far as they are in force on the date of signature of this Agreement or Agreement; or (b) any other provisions which may subsequently be introduced in Kazakhstan the Philippines in modification of, or in addition to, those the existing special incentive laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of the Philippines regarding the allowance as a credit against Philippine tax of tax payable in any country other than the Philippines, Malaysian tax payable in respect of income derived from Malaysia shall be allowed as a credit against the Philippine tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of Malaysia to a company which is a resident of the Philippines and which owns not less than 15 per cent of the voting shares of the company paying the dividend, the credit shall take in to account Malaysian tax payable by that company in respect of its income out of which the dividend is paid. The credit shall not, however, exceed that part of the Philippine tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Malaysian tax payable" shall be deemed to include Malaysian tax which would, under the laws of Malaysia and in accordance with this Agreement, have been payable on: (a) any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with: (i) sections 54A and 60A and Schedule 7A of the Income Tax Act, 1967 of Malaysia; or (ii) sections 21, 22, 26 and 30Q of the Investment Incentives Act, 1968 of Malaysia; so far as they were in force on the date of signature of this Agreement; and (iii) any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, the investment incentives laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character; (b) interest to which paragraph 3 of Article 11 applies had that interest not been exempted from Malaysian tax in accordance with that paragraph; and (c) approved industrial royalties to which paragraph 2(a)(ii) of Article 12 applies had those royalties not been exempted from Malaysian tax in accordance with that paragraph. 5. For the purposes of paragraph 3, where royalties derived by a resident of the Philippines are, as film rentals, subject to cinematograph film hire duty in Malaysia, that duty shall be deemed to be Malaysian tax.

ELIMINATION OF DOUBLE TAXATION. 1. Subject The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except where provisions to the laws contrary are made in this Convention. 2. The amount of Kazakhstan regarding the allowance as a credit against Kazakhstan Philippine tax of tax payable in any country other than Kazakhstanpayable, the Malaysian tax payable under the laws of Malaysia the Philippines and in accordance with the provisions of this Agreement Convention, whether directly or by deduction, by a resident of Kazakhstan India, in respect of profits or income derived from Malaysia arising in the Philippines, which have been subjected to tax both in India and in the Philippines, shall be allowed as a credit against Kazakhstan the Indian tax payable in respect of such profits or income provided that income. The such credit shall not, however, not exceed that part of the Kazakhstan tax, Indian tax (as computed before the credit is given, allowing any such credit) which is appropriate to the profits or income arising in the Philippines. Further, where such item of resident is a company by which surtax is payable in India, the credit aforesaid shall be allowed in the first instance against income-tax payable by the company in India and as to the balance, if any, against surtax payable by it in India. 23. For the purposes of paragraph 1, the The term "Malaysian Philippine tax payable" shall be deemed to include Malaysian the amount of Philippine tax which would, under would have been paid if the laws of Malaysia and Philippine tax had not been exempted or reduced in accordance with this Agreement, have been payable on any income derived from sources in Malaysia had the income not been taxed at a reduced rate or exempted from Malaysian tax in accordance with the provisions of this Agreement Convention and the special incentives under the Malaysian incentive laws for the promotion of designed to promote economic development of Malaysia which were in force the Philippines, effective on the date of signature of this Agreement Convention, or any other provisions which may subsequently be introduced in Malaysia the future in the Philippine taxation laws in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting laws. 34. Subject to the laws The amount of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan Indian tax payable under the laws of Kazakhstan India and in accordance with the provisions of this agreement Convention, whether directly or by deduction, by a resident of Malaysia the Philippines, in respect of profits or income derived from Kazakhstan arising in India, which has been subjected to tax both in India and the Philippines, shall be allowed as a credit against Malaysian Philippine tax payable in respect of such profits or income provided that income. The such credit shall not, however, not exceed that part of the Malaysian tax, Philippine tax (as computed before the credit is given, allowing any such credit) which is appropriate to such item of incomethe profits or income arising in India. 45. For the purposes of the credit referred to in paragraph 34, the term "Kazakhstan Indian tax payable" shall be deemed to include Kazakhstan tax any amount which would, under the laws of Kazakhstan and in accordance with this Agreement, would have been payable on as Indian tax for any income derived from sources in Kazakhstan had assessment year but for an exemption or reduction of tax granted for that year or any part thereof by the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with special incentive measures under the provisions of this Agreement and the special incentives under the Kazakhstan laws for the promotion Income-tax Act, 1961 (43 of 1961), which are designed to promote economic development of Kazakhstan which were in force on the date of signature of this Agreement development, or any other provisions which may subsequently be introduced in Kazakhstan hereafter in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterexisting provisions for promoting economic development in India.

ELIMINATION OF DOUBLE TAXATION. 1. Subject to the existing provisions of the laws of Kazakhstan regarding the allowance as a credit against Kazakhstan tax Philippines of tax payable in any country other than Kazakhstan, paid outside the Malaysian Philippines and to subsequent modifications of those provisions - which shall not affect the general principles thereof - tax payable under the laws of Malaysia and Nigeria on profits, income or gains arising in accordance with this Agreement by a resident of Kazakhstan in respect of income derived from Malaysia Nigeria shall be allowed as a credit against Kazakhstan deducted from any Philippines tax payable in respect of that incomesuch profits, income or gains. The credit deduction shall not, however, exceed that part of the Kazakhstan Philippine income tax, as computed before the credit deduction is given, which is appropriate to such item of incomeotherwise due on the income which may be taxed in Nigeria. 2. For Subject to the purposes provisions of paragraph 1, the term "Malaysian law of Nigeria regarding the allowances as a credit against Nigerian tax payable" of tax paid in a territory outside Nigeria (which shall be deemed to include Malaysian not affect the general principle hereof): a) Philippine tax which would, payable under the laws of Malaysia the Philippines and in accordance with this Agreement, have been payable whether directly or by deduction, on any profits, income derived or chargeable gains from sources within the Philippines (excluding in Malaysia had 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 Nigerian tax computed by reference to the same profits, income not been or chargeable gains by reference to which Philippine tax is computed. b) In the case of a dividend paid by a company which is a resident of the Philippines to a company which is a resident in Nigeria and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit shall take into (in addition to any Philippine tax for which credit shall take into account (in addition to any Philippine tax for which credit may be allowed under the provisions of sub-paragraph (a) of this paragraph) the Philippine tax payable by the company in respect of the profits out of which such dividend is paid. 3. If a resident of one of the States derives gains which may be taxed at a reduced rate or exempted from Malaysian tax in the other State in accordance with Article 13, that other State shall allow a deduction from its tax on such gains to an amount equal to the provisions tax levied in the first-mentioned State of this Agreement and the said gains. 4. Taxes which have been relieved or reduced in a Contracting State by virtue of special incentives under the Malaysian incentive laws for the promotion of economic development or by virtue of Malaysia which were in force on the date of signature of this Agreement or any other provisions which may subsequently be introduced in Malaysia in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar character. 3. Subject to the laws of Malaysia regarding the allowance as a credit against Malaysian tax of tax payable in any country other than Malaysia, the Kazakhstan tax payable under the laws of Kazakhstan and in accordance with this agreement by a resident of Malaysia in respect of income derived from Kazakhstan shall be allowed as a credit against Malaysian tax payable in respect of that income. The credit shall not, however, exceed that part of the Malaysian tax, as computed before the credit is given, which is appropriate to such item of income. 4. For the purposes of paragraph 3, the term "Kazakhstan tax payable" shall be deemed to include Kazakhstan tax which would, under the laws of Kazakhstan and in accordance with this Agreement, have been payable on any income derived from sources in Kazakhstan had the income not been taxed at a reduced rate or exempted from Kazakhstan tax in accordance with the provisions of this Agreement and shall be allowed as tax credit in the special incentives under other Contracting State in an amount equal to the Kazakhstan laws for tax which would have been appropriate to the promotion of economic development of Kazakhstan which were in force on the date of signature of this Agreement income involved if no such relief or any other provisions which may subsequently be introduced in Kazakhstan in modification of, or in addition to, those laws so far as they are agreed by the competent authorities of the Contracting States to be of a substantially similar characterreduction had been allowed.