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Article 23A - Exemption Method

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..... accordance with the provisions of this Convention except to the extent that these provisions allow taxation by that other State solely because the income is also income derived by a resident of that State or because the capital is also capital owned by a resident of that State, the Contracting State shall, exempt such income or capital from tax. [ Para 1 of Article 23B ] Ex .....

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..... tate first mentioned State shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in that other State. 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 that other State. [ Para 2 of Article 23B ] Where in accordance with .....

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..... se the capital is also capital owned by a resident of that State, the Contracting State shall, exempt such income or capital from tax. [ Para 1 of Article 23B ] Exception Income derived or capital owned by a resident of a Contracting State where the other Contracting State applies the provisions of this Convention to exempt such income or capital from tax or applies the prov .....

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..... e the deduction is given, which is attributable to such items of income which may be taxed in that other State. [ Para 2 of Article 23B ] Where in accordance with any provision of this Convention income derived or capital owned by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income or c .....

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