Artikel 22

1. Where a resident of Kyrgyzstan derives income which, in accordance with the provisions of this Agreement, may be taxed or shall be taxable only in the Netherlands, Kyrgyzstan shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the Netherlands. 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 which may be taxed or shall be taxable only in that other State.
2. Where in accordance with any provision of the Agreement income derived by a resident of Kyrgyzstan is exempt from tax in that State, Kyrgyzstan may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
3. The Netherlands, when imposing tax on its residents, may include in the basis upon which such taxes are imposed the items of income which, according to the provisions of this Agreement, may be taxed or shall be taxable only in Kyrgyzstan.
4. However, where a resident of the Netherlands derives items of income which according to paragraphs 1, 3 and 4 of Article 6, paragraph 1 of Article 7, paragraphs 1 and 3 of Article 8, paragraph 4 of Article 10, paragraph 5 of Article 11, paragraph 4 of Article 12, paragraphs 1 and 2 of Article 13, paragraph 1 of Article 14, paragraph 1 of Article 15, paragraph 1 of Article 18, paragraphs 1 (subparagraph a) and 2 (subparagraph a) of Article 19 and paragraph 2 of Article 21 of this Agreement may be taxed or shall be taxable only in Kyrgyzstan and are included in the basis referred to in paragraph 3, the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of Netherlands law for the avoidance of double taxation. For that purpose the said items of income shall be deemed to be included in the amount of the items of income which are exempt from Netherlands tax under those provisions.
5. Further, the Netherlands shall allow a deduction from the Netherlands tax so computed for the items of income which according to paragraphs 2 and 6 of Article 10, paragraph 2 of Article 11, paragraph 2 of Article 12, paragraph 5 of Article 13, Article 16 and paragraphs 1 and 2 of Article 17 of this Agreement may be taxed in Kyrgyzstan to the extent that these items are included in the basis referred to in paragraph 3.
The amount of this deduction shall be equal to the tax paid in Kyrgyzstan on these items of income, but shall, in case the provisions of the Netherlands law for the avoidance of double taxation provides so, not exceed the amount of the reduction which would be allowed if the items of income so included were the sole items of income which are exempt from Netherlands tax under the provisions of Netherlands law for the avoidance of double taxation.
This paragraph shall not restrict allowance now or hereafter accorded by the provisions of the Netherlands law for the avoidance of double taxation, but only as far as the calculation of the amount of the reduction of Netherlands tax is concerned with respect to the aggregate of income from more than one country.
6. Notwithstanding the provisions of paragraph 4, the Netherlands shall allow a deduction from the Netherlands tax for the tax paid in Kyrgyzstan on items of income which according to paragraph 1 of Article 7, paragraph 4 of Article 10, paragraph 5 of Article 11, paragraph 4 of Article 12, paragraph 1 of Article 14 and paragraph 2 of Article 21 of this Agreement may be taxed in Kyrgyzstan to the extent that these items are included in the basis referred to in paragraph 3, if and insofar as the Netherlands under the provisions of Netherlands law for the avoidance of double taxation allows a deduction from the Netherlands tax of the tax levied in another country on such items of income. For the computation of this deduction the provisions of paragraph 5 of this Article shall apply accordingly.