Page:United States Statutes at Large Volume 60 Part 2.djvu/308

 TREATIES Credits allowable. Claim for credit or tax refund. (b) in Great Britain in the case of property passing under a disposition governed by the law of Great Britain. ARTICLE V (1) Where one Contracting Party imposes tax by reason of a decedent's being domiciled in some part of its territory or being its national, that Party shall allow against so much of its tax (as otherwise computed) as is attributable to property situated in the territory of the other Contracting Party, a credit (not exceeding the amount of the tax so attributable) equal to so much of the tax imposed in the territory of such other Party as is attributable to such property; but this paragraph shall not apply as respects any such property as is men- tioned in paragraph (2) of this Article. (2) Where each Contracting Party imposes tax by reason of a decedent's being domiciled in some part of its territory, each Party shall allow against so much of its tax (as otherwise computed) as is attributable to property which is situated, or is deemed under para- graph (2) of Article III to be situated, (a) in the territory of both Parties, or (b) outside both territories, a credit which bears the same proportion to the amount of its tax so attributable or to the amount of the other Party's tax attributable to the same property, whichever is the less, as the former amount bears to the sum of both amounts. (3) For the purposes of this Article, the amount of the tax of a Contracting Party attributable to any property shall be ascertained after taking into account any credit, allowance or relief, or any remission or reduction of tax, otherwise than in respect of tax payable in the territory of the other Contracting Party or in any other country; and if, in respect of property situated outside the territories of both Parties, a Contracting Party allows against its tax a credit for tax payable in the country where the property is situated, that credit shall be taken into account in ascertaining, for the purposes of paragraph (2) of this Article, the amount of the tax of that Party attributable to the property. ARTICLE VI (1) Any claim for a credit or for a refund of tax founded on the provisions of the present Convention shall be made within six years from the date of the death of the decedent in respect of whose estate the claim is made, or, in the case of a reversionary interest where pay- ment of tax is deferred until on or after the date on which the interest falls into possession, within six years from that date. (2) Any such refund shall be made without payment of interest on the amount so refunded. ARTICLE VII tExchage of 'n- (1) The taxation authorities of the Contracting Parties shall ex- change such information (being information available under the 1394 [60 STAT.

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