It is understood that if the individual referred to in paragraph 5 of Article 13 is subject to tax on gains in the circumstances envisaged in that paragraph and the shares, ‘‘jouissance’’ rights or debt-claims were acquired before the individual became a resident of the first-mentioned State, that first-mentioned State shall consider that portion of the tax determined in accordance with the following formula to have been paid:
| A | = | X | x | Z |
| Y |
Where:
A = the amount of tax considered as paid;
X = the period of ownership during which the individual was not a resident of the first-mentioned State;
Y = the total period of ownership;
Z = the tax on the assessment.
This provision will only apply if the gain taxed in the first-mentioned State includes accrual of value during a period in which the individual was not a resident of that State.
