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Article 24 ELIMINATION OF DOUBLE TAXATION

Article 24
ELIMINATION OF DOUBLE TAXATION

 

1. In the case of a resident of the Russian Federation double taxation shall be eliminated as follows:

Where a resident of the Russian Federation derives income or owns capital, which in accordance with the provisions of this Agreement may be taxed in the Republic of Macedonia, the amount of tax on that income or capital payable in the Republic of Macedonia may be credited against the tax levied in the Russian Federation on that income or capital. The amount of credit, however, shall not exceed the amount of the tax computed in accordance with taxation laws and regulations of the Russian Federation.

2. In the case of a resident of the Republic of Macedonia double taxation shall be eliminated as follows:

Where a resident of the Republic of Macedonia derives income or owns capital which in accordance with the provisions of this Agreement may be taxed in the Russian Federation, the Republic of Macedonia shall allow:

1) as deduction from income tax of that resident an amount equal to the amount of income tax paid in the Russian Federation;

2) as a deduction from capital tax of the resident an amount equal to the amount of capital tax paid in the Russian Federation.

Such deductions shall not, however, exceed that part of the income tax or capital tax computed before the deduction is given, which is appropriate to the income or the capital which may be taxed in the Russian Federation.

3. Where in accordance with any provision of the Agreement 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 capital of such resident take into account the exempted income or capital.