Artikel II

In case a company is treated as a body corporate for tax purposes is liable as such to tax in a Contracting State, but the income of that company is taxed as income of the participants or owners in that entity (in proportion to their participation) in the other Contracting State, the competent authorities shall take such measures to prevent double taxation or double exemption. To this end, the competent authorities may agree to determine that each participant or owner may credit the tax levied on the income at the company level, as well as to agree on the possibility of abandoning taxation on the distribution of profits out of such company to its participants or owners.