SCHEDULE

Article 22 Elimination of double taxation
(1) Subject to the provisions of the law of the territory referred to in paragraph (3)(a) of Article 2 of this Agreement regarding the allowance as a credit against its tax of tax payable in another territory (which shall not affect the general principle hereof):
(a) Tax payable under the laws of the territory referred to in paragraph (3)(b) of Article 2 of this Agreement and in accordance with this Agreement, whether directly or by deduction, on profits, income or chargeable gains from sources within that territory (excluding in the case of a dividend, tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any tax payable under the laws of the territory referred to in paragraph (3)(a) of Article 2 of this Agreement computed by reference to the same profits, income or chargeable gains by reference to which the first mentioned tax is computed;
(b) in the case of a dividend paid by a company which is a resident of the territory referred to in paragraph (3)(b) of Article 2 of this Agreement to a company which is a resident of the territory referred to in paragraph (3)(a) of Article 2 of this Agreement and which controls directly or indirectly at least 10 per cent. of the voting power in the company paying the dividend, the credit shall take into account (in addition to any tax payable under the laws of the territory referred to in paragraph (3)(b) of Article 2 of this Agreement for which credit may be allowed under the provisions of sub-paragraph (a) of this paragraph) the tax payable under the laws of that territory by the company in respect of the profits out of which such dividend is paid.