4. Wages, salaries and other remuneration for personal services payable by a company or other taxable entity which is a resident of a Contracting State
In computing tax payable on its income or profits, there shall be allowed, to a company or other taxable entity which is a resident of a Contracting State and which is at least 20 per cent owned by a resident or residents of the other Contracting State, a deduction for actual wages, salaries and other remuneration for personal services paid by the company or other entity and incurred for the purpose of its trade or business.