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

METHODS FOR ELIMINATION OF DOUBLE TAXATION. § 1 In the case of Uzbekistan, double taxation shall be avoided as follows: a) Where a resident of Uzbekistan derives income or owns capital which, in accordance with the provisions of the Convention, may be taxed in Belgium, Uzbekistan shall allow -as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Belgium; -as a deduction from the property tax of that resident, an amount equal to the capital tax paid in Belgium. Such deduction in either case shall not, however, exceed that part of the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Belgium. b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Uzbekistan is exempt from tax in that State, Uzbekistan may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempt income or capital. § 2 In the case of Belgium, double taxation shall be avoided as follows: a) Where a resident of Belgium derives income or owns elements of capital which are taxed in Uzbekistan in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article ▇▇, ▇▇▇▇▇▇▇ shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraphs 2 or 7 of Article 11, or royalties taxable in accordance with paragraphs 2 or 6 of Article 12, the Uzbekistan tax levied on that income shall be allowedas a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Uzbekistan, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Uzbekistan, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment if and to the extent that those profits have also been exempted from tax in Uzbekistan by reason of compensation for thesaid losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. § 1 1. In the case of Uzbekistan, India double taxation shall be avoided eliminated as follows: a) Where a resident of Uzbekistan India derives income or owns capital which, in accordance with the provisions of the Conventionthis Agreement, may be taxed in BelgiumLuxembourg, Uzbekistan India shall allow -as as a deduction from the tax on the income or capital of that resident, an amount equal to the income tax paid in Belgium; -as a deduction from the property tax of that resident, an amount equal to the capital tax paid in Belgium. Such deduction in either case shall not, however, exceed that part of the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in BelgiumLuxembourg. b) Where in accordance with any provision of the Convention Agreement income derived or capital owned by a resident of Uzbekistan India is exempt from tax in that StateIndia, Uzbekistan India may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempt exempted income or capital. § 2 In 2. Subject to the case provisions of Belgiumthe law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be avoided eliminated as follows: a) Where a resident of Belgium Luxembourg derives income or owns elements of capital which are taxed in Uzbekistan which, in accordance with the provisions of this ConventionAgreement, other than those may be taxed in India, Luxembourg shall, subject to the provisions of paragraph 2 of Article 10sub-paragraphs b) and c), of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article ▇▇, ▇▇▇▇▇▇▇ shall exempt such income or such elements of capital from tax tax, but may, in calculating order to calculate the amount of tax on the remaining income or capital of that the resident, apply the rate same rates of tax which would have been applicable as if such the income or elements of capital had not been exempted. b) Subject to Where a resident of Luxembourg derives income which, in accordance with the provisions of Belgian law regarding Articles 10, 11, 12 and 17 may be taxed in India, Luxembourg shall allow as a deduction from the income tax on individuals or from the corporation tax of that resident an amount equal to the tax paid in India. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction from Belgian tax of taxes paid abroadis given, where a resident of Belgium derives which is attributable to such items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt derived from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraphs 2 or 7 of Article 11, or royalties taxable in accordance with paragraphs 2 or 6 of Article 12, the Uzbekistan tax levied on that income shall be allowedas a credit against Belgian tax relating to such incomeIndia. c) Dividends within the meaning The provisions of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Uzbekistan, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Uzbekistan, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to income derived or capital owned by a resident of Luxembourg where India applies the profits provisions of other taxable periods attributable this Agreement to that establishment if and to the extent that those profits have also been exempted exempt such income or capital from tax in Uzbekistan by reason or applies the provisions of compensation for thesaid lossesparagraph 2 of Articles 10, 11 or 12 to such income.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. § 1 1. In the case of UzbekistanRwanda, double taxation shall be avoided as follows: a) Where follows : Belgian tax paid by a resident of Uzbekistan derives Rwanda in respect of income or owns capital whichtaxable in Belgium, in accordance with the provisions of the this Convention, may shall be taxed in Belgium, Uzbekistan shall allow -as a deduction deducted from the tax on taxes due in accordance with the income of that resident, an amount equal to the income tax paid in Belgium; -as a deduction from the property tax of that resident, an amount equal to the capital tax paid in BelgiumRwandan fiscal law. Such deduction in either case deductions shall not, however, exceed the tax payable in Rwanda that part of would otherwise be payable on the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed taxable in Belgium. b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Uzbekistan is exempt from tax in that State, Uzbekistan may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempt income or capital. § 2 2. In the case of Belgium, double taxation shall be avoided as followsfollows : a) Where a resident of Belgium derives income income, not being dividends, interest or royalties, or owns elements of capital which are may be taxed in Uzbekistan Rwanda in accordance with the provisions of this Convention, other than those of paragraph 2 of Article 10and which are taxed there, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article ▇▇, ▇▇▇▇▇▇▇ Belgium shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. However, where the tax levied in Rwanda amounts to less than 15 per cent of the net amount of the income referred to in Article 7, Belgium shall not exempt that income but shall reduce to a half the Belgian tax which is proportionally relating to that income, calculated as if that income was income from Belgian sources. b) Where a resident of Belgium derives income from business operations which may be taxed in Rwanda in accordance with the provisions of Article 7 of this Convention but which are not effectively taxed according to special measures to promote economic development in Rwanda, Belgium shall also exempt such income from tax. However, in calculating the amount of tax on the remaining income or capital of that resident, Belgium may apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. This provision applies for a period of ten consecutive calendar years starting from the moment the Convention starts to have effect. The competent authorities of the Contracting States may decide by mutual agreement to extend this provision for a new period of ten years. c) Notwithstanding the provisions of sub-paragraphs a) and b) 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 B beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) or b) 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. d) Dividends derived by a company which is a resident of Belgium from a company which is a resident of Rwanda, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. Notwithstanding the condition of taxation provided for in Belgian law, dividends referred to in Article 10, paragraph 2, sub-paragraph 2 and derived by a company which is a resident of Belgium from a company which is a resident of Rwanda and which are paid out of profits from business operations in Rwanda which Rwanda exempts from the corporate income tax under special measures to promote economic development in Rwanda, shall also be exempt from the corporate income tax in Belgium. Belgium shall exempt these dividends during a period of ten years starting from the moment the Convention starts to have effect and in accordance with the other limits and conditions provided for in Belgian law. The competent authorities of the Contracting States may decide by mutual agreement to extend this provision for a new period of ten years. e) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraphs 2 or 7 of Article 11, or royalties taxable in accordance with paragraphs 2 or 6 of Article 12royalties, the Uzbekistan Rwandan tax levied on that income shall be allowedas allowed as a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Uzbekistan, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. df) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in UzbekistanRwanda, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph paragraphs a) and b) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment if and to the extent that those profits have also been exempted from tax in Uzbekistan Rwanda by reason of compensation for thesaid the said losses. Article 24 - Non-discrimination 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States. 2. Stateless persons who are residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of the State concerned in the same circumstances, in particular with respect to residence, are or may be subjected. 3. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, paragraph 6 of Article 12, or paragraph 6 of Article 13 apply, interest, royalties, technical fees and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. 6. The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. § 1 1. In the case of UzbekistanMauritius, double taxation shall be avoided as follows: (a) Where Subject to subparagraphs (b) and (c) hereinafter and to the provisions of the Mauritius legislation regarding the allowance as a resident credit against Mauritius tax of Uzbekistan derives income or owns capital which, tax paid abroad (in accordance with the provisions general principle of this Convention), where a resident of Mauritius derives profits, income or gains from Belgium which, under the laws of Belgium and in accordance with the Convention, may be taxed are taxable in Belgium, Uzbekistan whether directly or by withholding tax, Mauritius shall allow -as a deduction from credit against the Mauritius tax computed by reference to the same profits, income or gains by reference to which the Belgian tax is computed. (b) In the case of dividends, the credit provided for in subparagraph (a) shall only take into account such tax in respect thereof as is additional to the tax payable in Belgium by the distributing company on the income profits out of that residentwhich the dividends have been paid. (c) Where a company which is a resident of Mauritius derives dividends from a company which is a resident of Belgium and in which it holds directly or indirectly at least 10 per cent of the capital, an amount equal the credit allowed against the Mauritius tax shall take into account, in addition to the Belgian tax for which a credit is allowed under the provisions of subparagraphs (a) and (b), the Belgian tax payable by the distributing company in respect of the profits out of which the dividends have been paid. (d) For the purposes of this paragraph the profits, income tax paid and gains derived by a resident of Mauritius and which are taxable in Belgium; -as a deduction from the property tax of that resident, an amount equal Belgium according to the capital tax paid in Belgium. Such deduction in either case Convention shall not, however, exceed that part of the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, be deemed to the income or the capital which may be taxed arise in Belgium. b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Uzbekistan is exempt from tax in that State, Uzbekistan may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempt income or capital. § 2 2. In the case of Belgium, double taxation shall be avoided as follows: (a) Where a resident of Belgium derives income or owns elements of capital which are is taxed in Uzbekistan Mauritius in accordance with the provisions of this the Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 paragraph 5 of Article ▇▇, ▇▇▇▇▇▇▇ shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or capital of that resident, apply the rate of tax which would have been applicable if such income or elements of capital had not been exempted. However, this provision shall not apply to profits which a resident of Belgium derives from a permanent establishment situated in Mauritius and which have been taxed in Mauritius, but at a lower rate than 25 per cent. In such case, those profits may be taxed in Belgium in accordance with the provisions of the Belgian internal legislation regarding business income that has been derived and taxed abroad. (b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph (c) hereinafter, interest taxable in accordance with paragraphs 2 or 7 of Article 11, or royalties taxable in accordance with paragraphs 2 or 6 paragraph 5 of Article 12, the Uzbekistan Mauritius tax levied on that income shall be allowedas allowed as a credit against Belgian tax relating to such income. (c) Dividends within the meaning of paragraph 3 of Article 10, derived by Where a company which is a resident of Belgium from owns shares in a company which is a resident of UzbekistanMauritius, the dividends paid to it by the last-mentioned company and which are taxable in Mauritius in accordance with paragraph 2 of article 10 shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. (d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in UzbekistanMauritius, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph (a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment if and to the extent that those profits have also been exempted from tax in Uzbekistan Mauritius by reason of compensation for thesaid the said losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. § 1 1. In the case of Uzbekistan, India double taxation shall be avoided eliminated as followsfollows :— (a) Where a resident of Uzbekistan India derives income or owns capital which, in accordance with the provisions of the Conventionthis Agreement, may be taxed in BelgiumLuxembourg, Uzbekistan India shall allow -as as a deduction from the tax on the income or capital of that resident, an amount equal to the income tax paid in Belgium; -as a deduction from the property tax of that resident, an amount equal to the capital tax paid in BelgiumLuxembourg. Such deduction in either case shall not, however, exceed that part portion of the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in BelgiumLuxembourg. (b) Where in accordance with any provision of the Convention Agreement income derived or capital owned by a resident of Uzbekistan India is exempt from tax in that StateIndia, Uzbekistan India may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempt exempted income or capital. § 2 In 2. Subject to the case provisions of Belgiumthe law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be avoided eliminated as followsfollows :— (a) Where a resident of Belgium Luxembourg derives income or owns elements of capital which are taxed in Uzbekistan which, in accordance with the provisions of this ConventionAgreement, other than those may be taxed in India, Luxembourg shall, subject to the provisions of paragraph 2 of Article 10sub-paragraphs (b) and (c), of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article ▇▇, ▇▇▇▇▇▇▇ shall exempt such income or such elements of capital from tax tax, but may, in calculating order to calculate the amount of tax on the remaining income or capital of that the resident, apply the rate same rates of tax which would have been applicable as if such the income or elements of capital had not been exempted. (b) Subject to Where a resident of Luxembourg derives income which, in accordance with the provisions of Belgian law regarding Articles 10, 11, 12 and 17 may be taxed in India, Luxembourg shall allow as a deduction from the Income-tax on individuals or from the corporation tax of that resident an amount equal to the tax paid in India. 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 Belgian tax India. (c) The provisions of taxes paid abroad, where sub-paragraph (a) shall not apply to income derived or capital owned by a resident of Belgium derives items Luxembourg where India applies the provisions of his aggregate this Agreement to exempt such income for Belgian or capital from tax purposes which are dividends taxable in accordance with or applies the provisions of paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraphs 2 11 or 7 of Article 11, or royalties taxable in accordance with paragraphs 2 or 6 of Article 12, the Uzbekistan tax levied on that income shall be allowedas a credit against Belgian tax relating 12 to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Uzbekistan, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Uzbekistan, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment if and to the extent that those profits have also been exempted from tax in Uzbekistan by reason of compensation for thesaid losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. § 1 1. In the case of Uzbekistan, India double taxation shall be avoided eliminated as followsfollows :— (a) Where a resident of Uzbekistan India derives income or owns capital which, in accordance with the provisions of the Conventionthis Agreement, may be taxed in BelgiumLuxembourg, Uzbekistan India shall allow -as as a deduction from the tax on the income or capital of that resident, an amount equal to the income tax paid in Belgium; -as a deduction from the property tax of that resident, an amount equal to the capital tax paid in BelgiumLuxembourg. Such deduction in either case shall not, however, exceed that part portion of the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in BelgiumLuxembourg. (b) Where in accordance with any provision of the Convention Agreement income derived or capital owned by a resident of Uzbekistan India is exempt from tax in that StateIndia, Uzbekistan India may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempt exempted income or capital. § 2 In 2. Subject to the case provisions of Belgiumthe law of Luxembourg regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be avoided eliminated as followsfollows :— (a) Where a resident of Belgium Luxembourg derives income or owns elements of capital which are taxed in Uzbekistan which, in accordance with the provisions of this ConventionAgreement, other than those may be taxed in India, Luxembourg shall, subject to the provisions of paragraph 2 of Article 10subparagraphs (b) and (c), of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article ▇▇, ▇▇▇▇▇▇▇ shall exempt such income or such elements of capital from tax tax, but may, in calculating order to calculate the amount of tax on the remaining income or capital of that the resident, apply the rate same rates of tax which would have been applicable as if such the income or elements of capital had not been exempted. (b) Subject to Where a resident of Luxembourg derives income which, in accordance with the provisions of Belgian law regarding Articles 10, 11, 12 and 17 may be taxed in India, Luxembourg shall allow as a deduction from the Income- tax on individuals or from the corporation tax of that resident an amount equal to the tax paid in India. 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 Belgian tax India. (c) The provisions of taxes paid abroad, where sub-paragraph (a) shall not apply to income derived or capital owned by a resident of Belgium derives items Luxembourg where India applies the provisions of his aggregate this Agreement to exempt such income for Belgian or capital from tax purposes which are dividends taxable in accordance with or applies the provisions of paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraphs 2 11 or 7 of Article 11, or royalties taxable in accordance with paragraphs 2 or 6 of Article 12, the Uzbekistan tax levied on that income shall be allowedas a credit against Belgian tax relating 12 to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Uzbekistan, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Uzbekistan, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment if and to the extent that those profits have also been exempted from tax in Uzbekistan by reason of compensation for thesaid losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. § 1 1. In the case of UzbekistanIndia, double taxation shall be avoided eliminated as follows: a) Where a resident of Uzbekistan India derives income or owns capital which, in accordance with the provisions of the Conventionthis Agreement, may be taxed in BelgiumLithuania, Uzbekistan India shall allow -as allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Belgium; -as Lithuania; (ii) as a deduction from the property tax on the capital of that resident, an amount equal to the capital tax paid in BelgiumLithuania. Such deduction in either case shall not, however, exceed that part portion of the income tax or property capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in BelgiumLithuania. b) Where in accordance with any provision of the Convention Agreement income derived or capital owned by a resident of Uzbekistan India is exempt from tax in that StateIndia, Uzbekistan India may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempt exempted income or capital. § 2 2. In the case of BelgiumLithuania, double taxation shall be avoided eliminated as follows: Where a resident of Lithuania derives income or owns capital which, in accordance with this Agreement, may be taxed in India, unless a more favourable treatment is provided in its domestic law, Lithuania shall allow: a) Where as a resident of Belgium derives income or owns elements of capital which are taxed in Uzbekistan in accordance with deduction from the provisions of this Convention, other than those of paragraph 2 of Article 10, of paragraphs 2 and 7 of Article 11 and of paragraphs 2 and 6 of Article ▇▇, ▇▇▇▇▇▇▇ shall exempt such income or such elements of capital from tax but may, in calculating the amount of tax on the remaining income or of that resident, an amount equal to the income tax paid thereon in India; b) as a deduction from the tax on the capital of that resident, apply an amount equal to the rate capital tax paid thereon in India. Such deduction in either case shall not, however, exceed that part of the income tax or capital tax in Lithuania, as computed before the deduction is given, which would have been applicable if such is attributable, as the case may be, to the income or elements of the capital had not been exemptedwhich may be taxed in India. b) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are dividends taxable in accordance with paragraph 2 of Article 10, and not exempt from Belgian tax according to subparagraph c) hereinafter, interest taxable in accordance with paragraphs 2 or 7 of Article 11, or royalties taxable in accordance with paragraphs 2 or 6 of Article 12, the Uzbekistan tax levied on that income shall be allowedas a credit against Belgian tax relating to such income. c) Dividends within the meaning of paragraph 3 of Article 10, derived by a company which is a resident of Belgium from a company which is a resident of Uzbekistan, shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in Uzbekistan, have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment if and to the extent that those profits have also been exempted from tax in Uzbekistan by reason of compensation for thesaid losses.