The Double Taxation Relief (Taxes on Income) (Mongolia) Order 1996

(1) 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) Mongolian tax payable under the laws of Mongolia and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Mongolia (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 Mongolian tax is computed;

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