The Double Taxation Relief (Taxes on Income) (The Hashemite Kingdom of Jordan) Order 2001

Article 23 Elimination of double taxation

(1) In the case of Jordan:

• Where a resident of Jordan derives income from the United Kingdom, the amount of tax on that income payable in the United Kingdom in accordance with the provisions of this Convention, may be credited against the tax levied in Jordan imposed on that resident. The amount of credit, however, shall not exceed the amount of the tax in Jordan on that income computed in accordance with its taxation laws and regulations.

(2) In the case of the United Kingdom:

• Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom (which shall not affect the general principle hereof):

  (a)

  Jordanian tax payable under the laws of Jordan and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Jordan (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 United Kingdom tax computed by reference to the same profits, income or chargeable gains by reference to which the Jordanian tax is computed;

  (b)

  in the case of a dividend paid by a company which is a resident of Jordan to a company which is a resident of the United Kingdom 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 Jordanian tax for which credit may be allowed under the provisions of sub-paragraph (a) of this paragraph) the Jordanian tax payable by the company in respect of the profits out of which such dividend is paid.

(3) For the purposes of paragraph (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other Contracting State.