- 1
- Where under any provision of this Convention a Contracting State reduces the rate of tax on, or exempts from tax, income or capital gains and, under the law in force in the other Contracting State a person, in respect of that income or capital gains, is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the reduction or exemption to be allowed under this convention in the firstmentioned Contracting State shall apply only to so much of the income or capital gains as is taxed in the other Contracting State.
- 2
- However, the provision of paragraph 1 of this Article does not apply to income or capital gains derived by the Government, a political subdivision or local authority, or an agency of a Contracting State or the Central Bank of a Contracting State.
