In Spain. (a) Where a resident of Spain derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Luxembourg, Spain shall allow as a deduction from the tax on the income or capital of that resident, an amount equal to the income or capital tax paid in Luxembourg. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to the income or the capital which may be taxed in Luxembourg. (b) Where in accordance with any provision of the Convention income derived or capital owned by a resident of Spain is exempt from tax in Spain, Spain may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
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In Spain. (a) Where a resident of Spain derives income or owns capital capital, which, in accordance with the provisions of this Convention, may be taxed in Luxembourg, Spain shall allow as a deduction from the tax on the income or capital of that resident, resident an amount equal to the income or capital tax paid in Luxembourg. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to the income or the capital which may be taxed in Luxembourg.
(b) Where Where, in accordance with any provision of the Convention this Convention, income derived or capital owned by a resident of Spain is exempt from tax in Spain, Spain may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
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Sources: Income and Capital Tax Convention