Article 22 ELIMINATION OF DOUBLE TAXATION

1. Subject to the provisions of the laws of Japan regarding the allowance as a credit against Japanese tax of tax payable in any country other than Japan, where a resident of Japan derives income from Russia which may be taxed in Russia in accordance with the provisions of this Convention, the amount of Russian tax payable in respect of that income shall be allowed as a credit against the Japanese tax imposed on that resident. The amount of credit, however, shall not exceed the amount of the Japanese tax which is appropriate to that income.

2. Where a resident of Russia derives income from Japan, the amount of tax on that income payable in Japan in accordance with the provisions of this Convention shall be allowed to be credited against the Russian tax imposed on that resident. The amount of credit, however, shall not exceed the amount of the Russian tax on that income computed in accordance with the taxation laws and regulations of Russia.