ARTICLE 22Elimination of double taxation
(1) Where a resident of the Sultanate of Oman derives income, profits or chargeable gains which, in accordance with the provisions of this Agreement, may be taxed in the United Kingdom, the Sultanate of Oman shall allow as a deduction from the tax on the income or profits of that resident an amount equal to the income tax, corporation tax, or capital gains tax paid in the United Kingdom, whether directly or by deduction. Such deduction shall not, however, exceed that part of the income tax (as computed before the deduction is given) which is attributable to the income, profits or chargeable gains which may be taxed in the United Kingdom.
(2) 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)Omani tax payable under the laws of the Sultanate of Oman and in accordance with this Agreement, whether directly or by deduction, on profits, income or chargeable gains from sources within the Sultanate of Oman (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 Omani tax is computed;
(b)in the case of a dividend paid by a company which is a resident of the Sultanate of Oman 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 Omani tax for which credit may be allowed under the provisions of sub-paragraph (a) of this paragraph) the Omani tax payable by the company in respect of the profits out of which such dividend is paid.
(3) For the purposes of paragraphs (1) and (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 Agreement shall be deemed to arise from sources in that other Contracting State.