ARTICLE 24

Relief from Double Taxation

1. In the case of the United States, double taxation shall be avoided as follows: 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 the appropriate amount of tax paid or accrued to Jamaica; and, in the case of a United States company owning at least 10 per cent of the voting power of a company which is a resident of Jamaica from which it receives dividends in any taxable year, the United States shall allow as a credit against the United States tax on income the appropriate amount of tax paid or accrued to Jamaica by that company with respect to the profits out of which such dividends are paid. Such appropriate amount shall be based upon the amount of tax paid or accrued to Jamaica, but the credit shall not exceed the limitations (for the purpose of limiting the credit to the United States tax on income from sources outside of the United States) provided by United States law for the taxable year. For purposes of applying the United States credit in relation to tax paid or accrued to Jamaica the taxes referred to in paragraphs 2(b) and 3 of Article 2 (Taxes Covered) shall be considered to be income taxes.

2. In the case of Jamaica, double taxation shall be avoided as follows: In accordance with the provisions and subject to the limitations of the law of Jamaica (as it may be amended from time to time without changing the general principle hereof), Jamaica shall allow to a resident of Jamaica as a credit against Jamaican tax on income the appropriate amount of tax paid or accrued to the United States; and in the case of a Jamaican company owning at least 10 per cent of the voting power of a company which is a resident of the United States from which it receives dividends in any taxable year, Jamaica shall allow as a credit against Jamaican tax on income the appropriate amount of tax paid or accrued to the United States by that company with respect to the profits out of which such dividends are paid. Such appropriate amount shall be based upon the amount of tax paid or accrued to the United States, but the credit shall not exceed the limitations (for the purpose of limiting the credit to the Jamaican tax on income from sources outside of Jamaica) provided by Jamaican law for the taxable year. For purposes of applying the

Jamaican credit in relation to tax paid or accrued to the United States the taxes referred to in paragraphs 2(a) and 3 of Article 2 (Taxes Covered) shall be considered to be income taxes.

3. For the purpose of the preceding paragraphs of this Article, the source of income or profits shall be determined in accordance with the following rules:

(a) dividends described in Article 10 (Dividends) shall be deemed to arise in a Contracting State if paid by a company which is a resident of that State;

(b) interest, as defined in paragraph 2 of Article 11 (Interest), shall be deemed to arise in the State specified in paragraph 6 of Article 11;

(c) royalties, as defined in paragraph 3 of Article 12 (Royalties), shall be deemed to arise in the State specified in paragraph 6 of Article 12;

(d) except for income or profits referred to subparagraphs (a), (b), or (c) dividends and interest derived from a company described in paragraph 3 of Article 4 (Residence), and income described in paragraph 3 of Article 23 (Other Income), income or profits derived by a resident of a Contracting State which may be taxed in the other Contracting State (other than solely by reason of citizenship) in accordance with this Convention shall be deemed to arise in that other Contracting State.