ARTICLE 24

Relief from Double Taxation

1. It is understood that double taxation will be avoided in accordance with the following paragraphs of this Article.

2. When a resident of Venezuela derives income that, in accordance with the provisions of this Convention, may be taxed in the United States, Venezuela shall allow a relief to such resident. Such relief shall be allowed in accordance with the provisions and subject to the limitations of the law of Venezuela, as they may be amended from time to time without changing the principle hereof. The relief may consist alternatively of:

a) an exemption of such income from Venezuelan tax, or b) a credit against the Venezuelan tax on income.

3. 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 Venezuela 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 Venezuela and from which the United States company receives dividends, the income tax paid to Venezuela by or on behalf of the distributing company with respect to the profits out of which the dividends are paid. Such credit shall be allowed 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).