Article 22 Elimination of Double Taxation

The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income which, according to the provisions of this Convention, may be taxed in the United Arab Emirates.

However, where a resident of the Netherlands derives items of income which according to Article 6, Article 7, paragraph 7 of Article 10, paragraph 3 of Article 11, paragraph 3 of Article 12, paragraphs 1 and 2 of Article 13, paragraph 1 of Article 14, paragraphs 1 (subparagraph a) and 2 (subparagraph a) of Article 18, paragraph 2 of Article 21 of this Convention may be taxed in the United Arab Emirates and are included in the basis referred to in paragraph 1, the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the amount of the items of income which are exempt from Netherlands tax under those provisions.

Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraph 2 of Article 10, paragraph 1 of Article 15, paragraphs 1 and 2 of Article 16 and paragraphs 1 and 2 of Article 17 of this Convention may be taxed in the United Arab Emirates to the extent that these items are included in the basis referred to in paragraph 1. The amount of this deduction shall be equal to the tax paid in the United Arab Emirates on these items of income, but shall, in case the provisions of the Netherlands law for the avoidance of double taxation provides so, not exceed the amount of the reduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.

This paragraph shall not restrict allowance now or hereafter accorded by the provisions of the Netherlands law for the avoidance of double taxation, but only as far as the calculation of the amount of the reduction of Netherlands tax is concerned with respect to the aggregation of income from more than one country.

Notwithstanding the provisions of paragraph 2, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in the United Arab Emirates on items of income which according to Article 7, paragraph 7 of Article 10, paragraph 3 of Article 11, paragraph 3 of Article 12 and paragraph 2 of Article 21 of this Convention may be taxed in the United Arab Emirates to the extent that these items are included in the basis referred to in paragraph 1, if and insofar as the Netherlands under the provisions of Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 3 of this Article shall apply accordingly.

In the case of the United Arab Emirates: Where a resident of the United Arab Emirates derives income, profits or capital gains which in accordance with the provisions of this Convention may be taxed in the Netherlands, the United Arab Emirates shall allow as a deduction from tax on the income, profits or capital gains of that person an amount equal to the tax on income, profits or capital gains paid in the Netherlands. Such deduction shall not, however, exceed that part of the tax computed in the United Arab Emirates before the deduction is given, which is attributable to the income, profits or capital gains which may be taxed in the Netherlands.