- 1
- The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed, the items of income, which according to the provisions of this Convention may be taxed in Korea.
- 2
- Without prejudice to the application of the provisions concerning the compensation of losses in the unilateral regulations for the avoidance of double taxation the Netherlands shall allow a deduction from the amount of tax computed in conformity with the first paragraph of this Article equal to such part of that tax which bears the same proportion to the aforesaid tax, as the part of the income which is included in the basis mentioned in the first paragraph of this Article and may be taxed in Korea according to Articles 6 and 7, paragraph 5 of Article 10, paragraph 5 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 14, Article 15, paragraph 1 of Article 16, paragraph 1 of Article 17, and Article 20, of this Convention bears to the total income which forms the basis mentioned in the first paragraph of this Article.
- 3
- Further the Netherlands shall allow a deduction from the tax computed in accordance with the preceding paragraphs of this Article with respect to the items of income which may be taxed in Korea according to paragraph 2 of Article 10, paragraph 2 of Article 11, paragraph 2 of Article 12, Article 18, and paragraphs 2 and 3 of Article 19, and are included in the basis mentioned in paragraph 1 of this Article. The amount of this deduction shall be the lesser of the following amounts:
-
- a)the amount equal to the Korean tax;
- b)the amount of the Netherlands tax which bears the same proportion to the amount of tax computed in conformity with paragraph 1 of this Article, as the amount of the said items of income bears to the amount of income which forms the basis mentioned in paragraph 1 of this Article.
- 4
- Korea shall allow to a resident of Korea as a credit against Korean tax the appropriate amount of tax paid or to be paid to the Netherlands. Such appropriate amount shall be based upon the amount of tax paid or to be paid to the Netherlands but shall not exceed that proportion of Korean tax which the income which in accordance with the provisions of this Convention may be taxed in the Netherlands bears to the entire income subject to Korean tax.
