ARTICLE 23

Relief from Double Taxation

1. In accordance with the provisions and subject to the limitations of the law of the United States (as it may be amended from time to time without changing the general principle hereof), the United States shall allow to a resident or citizen of the United States as a credit against the United States tax on income:

a) the income tax paid to Barbados by or on behalf of such citizen or resident; and b) in the case of a United States company owning at least 10 percent of the voting stock of a company which is a resident of Barbados and from which the United States company receives dividends, the income tax paid to Barbados by or on behalf of the distributing company with respect to the profits out of which the dividends are paid.

For the purposes of this paragraph, the taxes referred to in paragraphs l b) and 2 of Article 2 (Taxes Covered) shall be considered income taxes.

2. In accordance with the provisions and subject to the limitations of the law of Barbados (as it may be amended from time to time without changing the general principle hereof) Barbados shall allow to a resident of Barbados as a credit against the Barbados tax on income:

a) the income tax paid to the United States by or on behalf of such resident; and b) in the case of a Barbados company owning at least 10 percent of the voting stock of a company which is a resident of the United States from which it receives dividends the income tax paid to the United States by or on behalf of the distributing company with respect to the profits out of which the dividends are paid.

For the purposes of this paragraph, the taxes referred to in paragraphs 1 a) and 2 of Article 2 (Taxes Covered) shall be considered income taxes. Credit allowed solely by reasons of the preceding sentence, when added to otherwise allowable credits for taxes referred to in paragraphs 1 a) and 2 of Article 2, shall not in any taxable year exceed that proportion of the Barbados tax on income which taxable income arising in the United States bears to total taxable income.

3. For the purposes of allowing relief from double taxation pursuant to this Article, income shall be deemed to arise exclusively as follows:

a) income derived by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention (other than solely by reason of citizenship in accordance with paragraph 3 of Article 1 (General Scope)) shall be deemed to arise in that other State:

b) income derived by a resident of a Contracting State which may not be taxed in the other Contracting State in accordance with the Convention shall be deemed to arise in the firstmentioned State.