Artikel 24 Overeenkomst tussen de Regering van het Koninkrijk der Nederlanden en de Regering van Japan tot het vermijden van dubbele belasting met betrekking tot belastingen naar het inkomen

Article 24 1 Where a resident of Japan derives income from the Netherlands and that income may be taxed in both countries in accordance with the provisions of this Convention, the amount of the Netherlands 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 that part of the Japanese tax which is appropriate to that income. The mode of application of giving this credit shall be determined in accordance with 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. 2 (a) The Netherlands, when imposing tax on its residents, may include in the basis upon which such tax is imposed the items of income, which according to the provisions of this Convention may be taxed in Japan. (b) Without prejudice to the application of the provisions concerning the compensation of losses in the unilateral regulations for the avoidance of double taxation, the Netherlands shall allow a deduction from the amount of tax computed in conformity with the provisions of sub-paragraph (a) equal to such part of that tax which bears the same proportion to the aforesaid tax, as the part of the income which is included in the basis meant in the provisions of -paragraph (a) and which may be taxed in Japan according to the provisions of Articles 7 and 8, paragraphs 1 and 2 of Article 14, Article 15, paragraphs 1 and 3 of Article 16, Articles 17 and 18, and paragraph 1 of Article 20 of this Convention bears to the total income which forms the basis meant in the provisions of sub-paragraph (a). (c) Further the Netherlands shall allow a deduction from the Netherlands tax so computed for such items of income, as are included in the basis meant in the provisions of subparagraph (a) and as may be taxed in Japan according to the provisions of paragraph 2 of Article 11, paragraph 2 of Article 12, paragraph 2 of Article 13, and paragraph 5 of Article 14. The amount of this deduction shall be equal to the amount of the Japanese tax. The deduction shall not, however, exceed that part of the Netherlands tax as computed before the deduction is given which is appropriate to the said items of income.