Artikel 6

1. Where this Agreement provides (with or without other conditions) that income shall be relieved wholly or partly from tax in one of the States and under the laws in force in the other State the said income in subject to tax by reference to the amount thereof which is remitted to or received in that other State and not by reference to the full amount thereof, then the relief to be allowed under this Agreement in the first-mentioned State shall apply only to so much of the income as is remitted to or received in that other State:
Provided that where –
(a) in accordance with the foregoing provisions of this Article, relief has not been allowed in the first instance in the first-mentioned State in respect of an amount of income; and
(b) that amount of income has subsequently been remitted to or received in the other State and is thereby subject to tax in that other State,
the first-mentioned State shall, subject to any laws thereof for the time being in force limiting the time and setting out the method for the making of a refund of tax, allow relief in respect of that amount of income in accordance with the appropriate provisions of this Agreement.
2. The provisions of Chapter III of this Agreement shall not apply to persons entitled to any special tax benefit under:
a) a law of either one of the States which has been identified in an Exchange of Notes between the States; or
b) any substantially similar law subsequently enacted.