Article 5

"b) Where a resident of Austria derives items of income which, in accordance with the provisions of Article 10 or paragraph 4 of Article 13, may be taxed in the Russian Federation, Austria shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the Russian Federation. 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 the Russian Federation."