Australian Tax Treaties
In the case of Israel double taxation shall be avoided as follows:
a) Where a resident of Israel derives income which, in accordance with the provisions of this Convention, may be taxed in Australia (except to the extent that the provisions of this Convention allow taxation by Australia solely because the income is also income derived by a resident of Australia), Israel shall (subject to the laws of Israel regarding the allowance of a credit of foreign taxes, which shall not affect the general principle contained in this paragraph) allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Australia.
b) Such deductions shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable to the income which may be taxed in Australia.
2.
Subject to the provisions of the laws of Australia which relate to the allowance of a credit against Australian tax of tax paid in a country outside Australia (which shall not affect the general principle of this Article), Israeli tax paid under the laws of Israel and in accordance with this Convention (except to the extent that the provisions of this Convention allow taxation by Israel solely because the income is also income derived by a resident of Israel), in respect of income derived by a resident of Australia shall be allowed as a credit against Australian tax payable in respect of that income.
3.
For the purposes of paragraphs 1 and 2, profits, income and 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 State.
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