Common use of METHODS FOR ELIMINATION OF DOUBLE TAXATION Clause in Contracts

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of the Isle of Man, double taxation shall be avoided as follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Guernsey. b) Where a resident of the Isle of Man derives income which, in accordance with the provisions of this Agreement, may be taxed in Guernsey the Isle of Man shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Guernsey. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Guernsey. c) Where in accordance with any provision of this Agreement income derived by a resident of the Isle of Man is exempt from tax in the Isle of Man, the Isle of Man may nevertheless in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 2. In the case of Guernsey, double taxation shall be avoided as follows: Subject to the provisions of the laws of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey (which shall not affect the general principle hereof): a) subject to the provisions of sub-paragraph c), where a resident of Guernsey derives income which, in accordance with the provisions of the Agreement, may be taxed in the Isle of Man, Guernsey shall allow as a deduction from the tax payable in respect of that income, an amount equal to the income tax paid in the Isle of Man; b) such deduction shall not, however, exceed that part of the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in the Isle of Man; c) where a resident of Guernsey derives income which, in accordance with the provisions of the Agreement shall be taxable only in the Isle of Man, Guernsey may include this income in calculating the amount of tax on the remaining income of such resident.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case The laws in either of the Isle contracting states shal continue to govern the taxation of Manincome in the respective Contracting States except where provisions to the contrary are made in this Agreement. Where income is subject to tax in both contracting states, relief from double taxation shall shal be avoided given in accordance with this Article. 2. Double taxation shal be eliminated as followsfol ows: (i) In India: (a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Guernsey. b) Where a resident of the Isle of Man India derives income which, in accordance with the provisions of this Agreement, may be taxed in Guernsey the Isle of Man shall allow Bhutan, India shal al ow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in GuernseyBhutan. Such deduction shall shal not, however, exceed that part portion of the income tax, tax as computed before the deduction is given, which is attributable attributable, as the case may be, to the income which may be taxed in GuernseyBhutan. c(b) Where in accordance with any provision of this the Agreement income derived by a resident of the Isle of Man India is exempt from tax in the Isle of ManIndia, the Isle of Man India may nevertheless nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 2. (ii) In the case of Guernsey, double taxation shall be avoided as follows: Subject to the provisions of the laws of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey Bhutan: (which shall not affect the general principle hereof): a) subject to the provisions of sub-paragraph c), where Where a resident of Guernsey Bhutan derives income which, in accordance with the provisions of the this Agreement, may be taxed in the Isle of ManIndia, Guernsey shall allow Bhutan shal al ow as a deduction from the tax payable in respect on the income of that incomeresident, an amount equal to the income tax paid in the Isle of Man; b) such India. Such deduction shall shal not, however, exceed that part portion of the income tax, tax as computed before the deduction is given, which is attributable attributable, as the case may be, to the income which may be taxed in India. (b) Where in accordance with any provision of the Isle of Man; c) where Agreement, income derived by a resident of Guernsey derives income whichBhutan is exempt from tax in Bhutan, in accordance with the provisions of the Agreement shall be taxable only in the Isle of ManBhutan may nevertheless, Guernsey may include this income in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 3. The tax payable by an enterprise (being a permanent establishment) in Bhutan mentioned in paragraphs 1 and 2 of this ARTICLE shal be deemed to include the tax which would have been payable but for the fol owing tax incentives in education and health sectors granted under the Fiscal Incentives, 2010 issued by Ministry of Finance, Royal Government of Bhutan (vide Notification Ref No. DRC/XXX­X&X/HOL/2010/3656 dated 2nd April, 2010) which are designed to promote economic development in Bhutan: (i) Education sector: An educational or vocational institute established outside Thimphu and Phuentsholing cities (with a minimum enrofment capacity of 200 students); (ii) Health sector: A high end private health service centre or hospital (with a minimum project cost of Rs/Nu 200 mil ion). 4. Notwithstanding the provisions of paragraph 3, Bhutanese tax shal not be deemed to have been paid under that paragraph of this ARTICLE in respect of: (i) income by way of dividends, interest, capital gains or from activities not directly connected with the running of educational or vocational institute or health service centre or hospital, as the case may be; or (ii) income derived from any arrangement, entered into by an Indian resident, covered by the provisions of ARTICLE 27(Limitation of Benefits) of the Agreement. 5. The provisions of paragraph 3 shal apply for the first seven years from the date of entry into force of this Agreement. This period may be extended by mutual agreement between the competent authorities.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of the Isle of ManEstonia, double taxation shall be avoided in accordance with the provisions and subject to the limitations of the laws of Estonia (as it may be amended from time to time without changing the general principle hereof), as follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Guernsey. b) Where where a resident of the Isle of Man Estonia derives income which, in accordance with the provisions of this Agreement, has been taxed in Guernsey, Estonia shall, subject to the provisions of subparagraph b) and paragraph 3, exempt such income from tax; b) where a resident of Estonia derives income which in accordance with paragraph 2 of Articles 10, 11 and 12 or paragraphs 1 and 2 of Article 16 may be taxed in Guernsey the Isle of Man Guernsey, Estonia shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income tax paid in Guernsey. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Guernsey. c) Where in accordance with any provision of this Agreement income derived by a resident of the Isle of Man is exempt from tax in the Isle of Man, the Isle of Man may nevertheless in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 2. In the case of Guernsey, double taxation shall be avoided as follows: . Subject to the provisions of the laws of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey (which shall not affect the general principle hereof): a) subject to the provisions of sub-paragraph c)3, where a resident of Guernsey derives income which, in accordance with the provisions of the Agreement, may be taxed in the Isle of ManEstonia, Guernsey shall allow as a deduction from the tax payable in respect of that income, an amount equal to the income tax paid in the Isle of ManEstonia; b) such deduction shall not, however, exceed that part of the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in the Isle of Man;Estonia. c) where a resident of Guernsey derives income which3. Where, in accordance with the provisions any provision of the Agreement shall be this Agreement, income derived by a resident of a Party is not taxable only in the Isle of Manthat Party, Guernsey such Party may include this income nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of the Isle of Man, double taxation shall be avoided as follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in GuernseyBelgium. b) Where a resident of the Isle of Man derives income which, in accordance with the provisions of this Agreement, may be taxed in Guernsey Belgium the Isle of Man shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in GuernseyBelgium. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in GuernseyBelgium. c) Where in accordance with any provision Notwithstanding the provisions of this Agreement income derived by sub-paragraph b), where a company which is a resident of the Isle of Man holds, for an uninterrupted period of at least twelve months, directly at least 10 per cent of the capital of a company which is exempt from tax in the Isle a resident of ManBelgium paying dividends, the Isle of Man shall exempt from tax the dividends paid to the company which is a resident of the Isle of Man by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may nevertheless be taxed in the Isle of Man in accordance with the provisions of this Agreement, and which are taxed there, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of such that resident, take into account apply the exempted income. 2rate of tax which would have been applicable if such income had not been exempted. In However, in the case of Guernseya company which is a resident of Belgium, double taxation where the Manx tax is less than 10 per cent of the net amount of the income referred to in this sub-paragraph, Belgium shall be avoided not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as follows: Subject to the if that income were income from Belgian sources. The preceding provisions of this sub-paragraph shall also apply to income treated as dividends under Belgian law, which is derived by a resident of Belgium from a participation in an entity that derives its status as such from the laws of Guernsey regarding the allowance Isle of Man, where that entity has not been taxed as a credit against Guernsey tax such in the Isle of tax payable Man, provided that the resident of Belgium has been taxed in a territory outside Guernsey (which shall not affect the general principle hereof):Isle of Man on his share of the income of that entity. The exempted income is the income received after deduction of the costs incurred in Belgium or elsewhere in relation to the management of the participation in the entity. ab) subject to Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Agreement, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels or beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c)) Dividends derived by a company which is a resident of Belgium from a company which is a resident of the Isle of Man shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. However, this exemption shall apply when the income out of which the dividends are paid is taxed in the Isle of Man at a rate of not less than 10 per cent. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Guernsey Belgium derives items of his aggregate income whichfor Belgian tax purposes which are interest or royalties, the Manx tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with the provisions Belgian law, losses incurred by an enterprise carried on by a resident of the Agreement, may be taxed Belgium in a permanent establishment situated in the Isle of Man, Guernsey shall allow as a deduction Man have been effectively deducted from the tax payable in respect profits of that incomeenterprise for its taxation in Belgium, an amount equal the exemption provided for in sub-paragraph a) shall not apply in Belgium to the income profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax paid in the Isle of Man; b) such deduction shall not, however, exceed that part Man by reason of compensation for the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in the Isle of Man; c) where a resident of Guernsey derives income which, in accordance with the provisions of the Agreement shall be taxable only in the Isle of Man, Guernsey may include this income in calculating the amount of tax on the remaining income of such residentsaid losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of the Isle of ManEstonia, double taxation shall be avoided as follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Guernsey. b) Where where a resident of the Isle of Man Estonia derives income which, in accordance with the provisions of this Agreement, has been taxed in Kyrgyzstan, Estonia shall, subject to the provisions of sub-paragraph b), exempt such income from tax; b) where a resident of Estonia derives income which in accordance with the provisions of sub-paragraph b) of paragraph 2 of Article 10, or paragraph 2 of Articles 11 or 12 may be taxed in Guernsey the Isle of Man Kyrgyzstan, Estonia shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the income tax paid in GuernseyKyrgyzstan. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Guernsey.Kyrgyzstan; c) Where where in accordance with any provision of this the Agreement income derived by a resident of the Isle of Man Estonia is exempt from tax in the Isle of ManEstonia, the Isle of Man Estonia may nevertheless nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 2. In the case of GuernseyKyrgyzstan, double taxation shall be avoided as follows: Subject to the provisions of the laws of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey (which shall not affect the general principle hereof):: a) subject to the provisions of sub-paragraph c), where Where a resident of Guernsey Kyrgyzstan derives income which, in accordance with the provisions of the this Agreement, may be taxed in the Isle of Man, Guernsey Estonia Kyrgyzstan shall allow as a deduction from the tax payable in respect on the income of that incomeresident, an amount equal to the income tax paid in Estonia. The amount of the Isle of Man;tax deducted in accordance with the aforementioned provisions shall not exceed the tax, which would have been charged to this income by the rates effective in Kyrgyzstan. b) such deduction shall not, however, exceed that part of the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in the Isle of Man; c) where Where a resident of Guernsey Kyrgyzstan derives income which, which in accordance with the provisions of the this Agreement shall be taxable only in the Isle of ManEstonia, Guernsey Kyrgyzstan may include this income in calculating the tax base, but only for the purpose of establishing the tax rate for such income being applicable for taxation in Kyrgyzstan. 3. Notwithstanding the provisions of paragraphs 1 and 2, where a company that is a resident of a Contracting State receives a dividend from a company that is a resident of the other Contracting State in which it owns at least 10 per cent of its shares having full voting rights, the first-mentioned State shall allow as a deduction from the tax of that resident an amount of equal to the income tax paid in that other State by the company on the remaining income profits out of such residentwhich the dividend is paid.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of the Isle of ManSan Marino, double taxation shall be avoided as followsfollows : a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Guernsey. b) Where a resident of the Isle of Man San Marino derives income which, in accordance with the provisions of this AgreementConvention, may be taxed in Guernsey Belgium, San Marino shall, subject to the Isle provisions of Man sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in GuernseyBelgium. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in Guernsey. c) Where San Marino in accordance with any provision the provisions of this Agreement Convention, and which are taxed there, Belgium shall exempt such income derived by a resident of the Isle of Man is exempt from tax in the Isle of Manbut may, the Isle of Man may nevertheless in calculating the amount of tax on the remaining income of such that resident, take into account apply the exempted income. 2rate of tax which would have been applicable if such income had not been exempted. In However, in the case of Guernseya company which is a resident of Belgium, double taxation shall be avoided as follows: Subject to where the provisions San Marino tax is less than 15 per cent of the laws net amount of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable income referred to in a territory outside Guernsey (which this provision, Belgium shall not affect exempt that income, but reduce to a third the general principle hereof):Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. ab) subject to Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels – beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c)) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Guernsey Belgium derives items of his aggregate income whichfor Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with the provisions of the AgreementBelgian law, may be taxed in the Isle of Man, Guernsey shall allow as a deduction from the tax payable in respect of that income, losses incurred by an amount equal to the income tax paid in the Isle of Man; b) such deduction shall not, however, exceed that part of the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in the Isle of Man; c) where enterprise carried on by a resident of Guernsey derives income whichBelgium in a permanent establishment situated in San Marino have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in accordance with sub-paragraph a) shall not apply in Belgium to the provisions profits of other taxable periods attributable to that establishment to the Agreement shall be taxable only extent that those profits have also been exempted from tax in San Marino by reason of compensation for the Isle of Man, Guernsey may include this income in calculating the amount of tax on the remaining income of such residentsaid losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. Subject to the provisions of 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 the Isle of Man, Luxembourg shall, subject to the provisions of sub-paragraphs b), c) and d), 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 income which, in accordance with the provisions of Articles 7, 10, 13(2) and 16 may be taxed in the Isle of Man, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the Isle of Man, but only, with respect to Articles 7 and 13(2), if the business profits and the capital gains are not derived from activities in agriculture, industry, infrastructure and tourism in the Isle of Man. 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 the Isle of Man; c) where a company which is a resident of Luxembourg derives dividends from Isle of Man 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 to the Isle of Man tax corresponding to the Luxembourg corporation tax. The above-mentioned shares in the Isle of Man company are, under the same conditions, exempt from the Luxembourg capital tax. This exemption under this sub-paragraph shall also apply notwithstanding that the Isle of Man company is exempted from tax or taxed at a reduced rate in the Isle of Man and if these dividends are derived out of profits from activities in agriculture, industry, infrastructure or tourism in the Isle of Man; d) the provisions of sub-paragraph a) shall not apply to income derived or capital owned by a resident of Luxembourg where the Isle of Man applies the provisions of this Agreement to exempt such income or capital from tax or applies the provisions of paragraph 2 of Article 10 to such income. 2. In the case of the Isle of Man, double taxation shall be avoided as follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in GuernseyLuxembourg. b) Where a resident of the Isle of Man derives income which, in accordance with the provisions of this Agreement, may be taxed in Guernsey Luxembourg the Isle of Man shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in GuernseyLuxembourg. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in GuernseyLuxembourg. c) Where in accordance with any provision of this Agreement income derived by a resident of the Isle of Man is exempt from tax in the Isle of Man, the Isle of Man may nevertheless in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 2. In Note 24: The Isle of Man has reserved the case right for the entirety of Guernsey, double taxation shall be avoided as follows: Subject to the provisions Articles 3 and 5 of the laws MLI not to apply to this Agreement so there have been no changes to this Article notwithstanding that Luxembourg has decided to apply Option A of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey (which shall not affect the general principle hereof): a) subject to the provisions of sub-paragraph c), where a resident of Guernsey derives income which, in accordance with the provisions Article 5 of the Agreement, may be taxed in MLI. Luxembourg has reserved the Isle right for paragraph 2 of Man, Guernsey shall allow as a deduction from the tax payable in respect of that income, an amount equal to the income tax paid in the Isle of Man; b) such deduction shall not, however, exceed that part Article 3 of the income tax, as computed before deduction is given, which is attributable MLI not to the income which may be taxed in the Isle of Man; c) where a resident of Guernsey derives income which, in accordance with the provisions of the Agreement shall be taxable only in the Isle of Man, Guernsey may include apply to this income in calculating the amount of tax on the remaining income of such residentAgreement.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of the Isle of ManSan Marino, double taxation shall be avoided as followsfollows : a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Guernsey. b) Where a resident of the Isle of Man San Marino derives income which, in accordance with the provisions of this AgreementConvention, may be taxed in Guernsey Belgium, San Marino shall, subject to the Isle provisions of Man sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in GuernseyBelgium. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in Guernsey. c) Where San Marino in accordance with any provision the provisions of this Agreement Convention, and which are taxed there, Belgium shall exempt such income derived by a resident of the Isle of Man is exempt from tax in the Isle of Manbut may, the Isle of Man may nevertheless in calculating the amount of tax on the remaining income of such that resident, take into account apply the exempted income. 2rate of tax which would have been applicable if such income had not been exempted. In However, in the case of Guernseya company which is a resident of Belgium, double taxation shall be avoided as follows: Subject to where the provisions San Marino tax is less than 15 per cent of the laws net amount of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable income referred to in a territory outside Guernsey (which this provision, Belgium shall not affect exempt that income, but reduce to a third the general principle hereof):Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. ab) subject to Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels - beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c)) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Guernsey Belgium derives items of his aggregate income whichfor Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with the provisions of the AgreementBelgian law, may be taxed in the Isle of Man, Guernsey shall allow as a deduction from the tax payable in respect of that income, losses incurred by an amount equal to the income tax paid in the Isle of Man; b) such deduction shall not, however, exceed that part of the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in the Isle of Man; c) where enterprise carried on by a resident of Guernsey derives income whichBelgium in a permanent establishment situated in San Marino have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in accordance with sub-paragraph a) shall not apply in Belgium to the provisions profits of other taxable periods attributable to that establishment to the Agreement shall be taxable only extent that those profits have also been exempted from tax in San Marino by reason of compensation for the Isle of Man, Guernsey may include this income in calculating the amount of tax on the remaining income of such residentsaid losses.