in Singapore. Where a resident of Singapore derives income from Slovenia which, in accordance with the provisions of this Agreement, may be taxed in Slovenia, Singapore shall, subject to its laws regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, allow the Slovenian tax paid, whether directly or by deduction, as a credit against the Singapore tax payable on the income of that resident. Where such income is a dividend paid by a company which is a resident of Slovenia to a resident of Singapore which is a company owning directly or indirectly not less than 10 per cent of the share capital of the first-mentioned company, the credit shall take into account the Slovenian tax paid by that company on the portion of its profits out of which the dividend is paid.
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