제19695호                                관                보              2020. 2. 24.(월요일)
        a)     where    a resident   of   the   United   Arab Emirates derives income      which,   in
        accordance with the provisions of this Convention, may be taxed in Korea, the United
        Arab Emirates shall allow as a deduction from the tax on the income of that resident, an
        amount equal to the income tax paid in Korea. Such deduction in either case shall not,
        however, exceed that part of the income tax, as computed before the deduction is given,
        which is attributable, as the case may be, to the income which may be taxed in Korea;
        b)     where in accordance with any provision of the Convention income derived by a
        resident of the United Arab Emirates is exempt from tax in the United Arab Emirates,
        the United Arab Emirates may nevertheless, in calculating the amount of tax on the
        remaining income of such resident, take into account the exempted income.
                                                Article 22
                                     NON-DISCRIMINATION
1.      Nationals of a Contracting State shall not be subjected in the other Contracting State to
any taxation or any requirement connected therewith, which is other or more burdensome than
the taxation and connected requirements to which nationals of that other Contracting State in the
same circumstances, in particular with respect to residence, are or may be subjected.
2.      The taxation on a permanent establishment which an enterprise of a Contracting State
has in the other Contracting State shall not be less favourably levied in that other Contracting
State than the taxation levied on enterprises of that other State, carrying on the same activities.
This provision shall not be construed as obliging a Contracting State to grant to residents of the
other Contracting State any personal allowances, reliefs and reductions for taxation purposes on
account of civil status or family responsibilities which it grants to its own residents.
3.      Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or
paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise
of a Contracting State to a resident of the other Contracting State shall, for the purpose of
determining the taxable profits of such enterprise, be deductible under the same conditions as if
they had been paid to a resident of the first-mentioned State.
4.      Enterprises of a Contracting State, the capital of which is wholly or partly owned or
controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not
be subjected in the first-mentioned Contracting State to any taxation or any requirement
connected therewith which is other or more burdensome than the taxation and connected
requirements to which other similar enterprises of the first-mentioned State are or may be
subjected.
5.      The provisions of this Article shall apply to taxes subject to the Convention.
                                                Article 23
                             MUTUAL AGREEMENT PROCEDURE
                                                    37