Where under any provision of this Convention any income is
relieved from tax in a Contracting State and, under the law in
force in the other Contracting State a person, in respect of that
income, is subject to tax by reference to the amount thereof which
is remitted to or received in that other Contracting State and not
by reference to the full amount thereof, then the relief to be
allowed under this Convention in the first-mentioned Contracting
State shall apply only to so much of the income as is taxed in the
other Contracting State.
Notwithstanding the provisions of any other Article of this
Convention, a resident of a Contracting State who, as a consequence
of domestic law concerning incentives to promote foreign
investment, is not subject to tax or is subject to tax at a reduced
rate in that Contracting State on income or capital gains, shall
not receive the benefit of any reduction in or exemption from tax
provided for in this Convention by the other Contracting State if
the main purpose or one of the main purposes of such resident or
person connected with such resident was to obtain the benefits of
this Convention.
