Article 23 - Elimination of double taxation - Uganda

ARTICLE 23 ELIMINATION OF DOUBLE TAXATION 1. The laws in force in either of the Contracting States will continue to govern the taxation of income in the respective Contracting States except where provisions to the contrary are made in this Convention. 2. In the case of Uganda double taxation shall be eliminated as follows: Where a resident of Uganda derives income which, in accordance with the provisions of this Convention, may be taxed in India, Uganda shall allow as a deduction from the tax on the income of that resident an amount equal to the income-tax paid in India. Such deduction shall not, however, exceed that part of the income-tax as computed before the deduction is given, which is attributable to the income which may be taxed in India. 3. In the case of India double taxation shall be eliminated as follows: Where a resident of India derives income which, in accordance with the provisions of this Convention, may be taxed in Uganda, India shall allow as a deduction from the tax on the income of that resident an amount equal to the income-tax paid in Uganda whether directly or by deduction at source. Such amount shall not, however exceed that part of the income-tax as computed before the deduction is given, which is attributable to the income which may be taxed in Uganda. 4. The tax payable in the Contracting State mentioned in paragraph 2 and 3 of this Article shall be deemed to include the tax which would have been payable but for the tax incentives granted under the laws of the Contracting State and which are designed to promote economic development. 5. Income which, in accordance with the provisions of this Convention, is not to be subjected to tax in a Contracting State, may be taken into account for calculating the rate of tax to be imposed in that Contracting State.