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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
-
(5)
Vihere, lJursuant to
ans
provision of this Convention,
a
Contractiηg
State reduces the rate of tax
οη,
or exempts,
lncome
ο!
a resident
ο!
the other Contracting State and
under the 1a\'1 in force in that other Contracti.ng State
the resident is subject to tax by that other Contracting
State
οη1Υ οη
that part of Buch income which is remitted
to or received in that other Contracting State, then the
reduction or exemption shal1 app1y only to
θΟ
much ofsuch
1ncome
ΒΒ
is remitted to or received
ίη
that other
Contracting 5tate during the calendar year such income
11
ρβίά
or the next
~~
ca1endar year.
(6)
Where, pursuant to
any
prov~s~on ο!
this Convention
o\h.r
than paragraph 1 of Article 23 (Frivate Fensions
&Δd AΔnuitiee),
a Contracting State reduces th- rate of
ιaz ΟΔ.
or
exempts, income
ο!
a person who is a resident
.,
\~
other Contracting State
βηά
under the 1aw in force
ιa
tbat
other Contracting State such income is eubject to
423
• "'e
οΙ
tax or tax burden which is substantial1y less than
the tax which generally would be imposed
by
that Contracting
State
οη
such income
ί!
derived from sources within that
Contracting State, then the reduction or exemption to be
allowed under this
Co~vention ίη
the first-mentioned
Contracting State ehall not apply.
Article
5
RELIEF FROr-: DOUBLE
ΤΑΧΑΤΙΟΝ
Double taxation of income shall be avoided in the
following manner:
(1)
Ιη
accordance with the
prov~B~ons
and subject to the
limitations
ο!
the law
ο!
the United States (as it may be
amended from time to time without changing the princip1es
hereof), the United States ahall allow to a citizen or
resident
ο!
the United States
βθ
a credit against the United
States tax the appropriate amount of the Cypriot tax.
However,
ηο
such credit shall be allowed with respect to
dividends paid by a Cypriot corporation to a resident
ο!
the
United States, other than a United States corporation owning
at least 10 percent of the voting power of such Cypriot
corporation.
Ιη
the case of such a United States corporation,
the United States shall allow
βθ
a credit against the United