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May 15, 2026

Part 4 - Avoidance of Double Taxation

Chapter 1 - Avoidance of International Double Taxation

Article 122

[GTL Notes: Foreign Tax Credit Limits]

The amount allowed to be deducted for the foreign tax, for any tax year, shall not exceed the difference between the amount of tax which would be chargeable on the taxable income for that year before the deduction for the foreign tax, and the amount of tax which would be chargeable on that income after deducting the income for which the deduction is to be allowed.

In all cases, the total amount allowed to be deducted for any tax year for the foreign tax under this Chapter shall not exceed the tax payable for that year.