Page 433 - ΔΟΚΙΜΗ

424 ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ 1984
States tax οη income the appropriate amount of the Cypriot
\aχ paid by the Cypriot corporation with respect to the
protits out of which the dividends are pald to the United
States corporation. Where a credit 1e a110wed pureuant to
thls paragraph. suoh appropriate amount shall be baeed upon
\he amount of the Cypriot tax pa1d, but the credit ehall not
8xceed the limitations provided by United States law for the
\axable ,ear. lor the purpoee ΟΙ apply1ng the United Statea
eredlt ln relation to taxes paid to Cyprus, the rulee set
fortb ln Article 6 (Source ο! Iηco~θ) ehal1 be arp1ied to
4.t.~ne the eource ο! income.
(2) ΙΔ accordanoe with the provisione and subject to the
1181ΙβΙ10Δ8 ot the law ο! Cyprus (ββ it may be amended from
\1.. \0 tiJDe w1 thout ohangi.ng the prinoiJ:I1es hereof), Cyprue
8.. ]1 &110w to a citizen or resident of Oy~rus 8θ 8 credit
eμ1Ω8Ι \h. Cypriot tax the apI,ropriate amount ΟΙ the ΌηΙ ted
States tax and, ίη the Case οί' a Cypriot corpor'ation owning
at least 10 percent of the voti.r.g power 01' a United States
CCTrιoration fronI y.'hich i t received dividends ίιι any taxable
,
year, shall allow credit for the appropriate amount of the
United statee tax paid by the United States corporation
paying such dividends with respect to the profits out of
\\'hich suclI dividends are paid. Suoh appropriate arnount shall
be based ιιροη the amount οί' the United 5tates tax paid but
sha11 not exceed that portion of the Cypriot te.x, Β8 CODlputed
before the credit 18 glven, which i8 applicable to such items
ο"! incoule. For the purpose ο! app1ying the Cypriot credi t
1η relation to taxes paid to the United States, the rules set
forth Ιη Article 6 (Source of Income) ehall be applied to
determine the θΟΙΙΤCθ of ίnCΟDΊe.
Article 6
SOURCE OF INCOME
.
For !·ΙΙΤΙί οβθθ 01' this Conventj οη:
(1) Dlvidends shal1 be treated βθ income from sources
within a Contractjng State only if pald by a corporation 0'1
that Contracting State. Notwithstending the preceding
sentence, if the dividends are described ίη paragraph 4(b)
of Article 12 (Dividends), or 8re dividends paid by β
corI,oratjon (other than a resident of a Contracting state)
whicb derives 50 percent or more of its total gross income