9.1. Unilateral and Treaty Based Methods Available for the Elimination or Mitigation of Double Taxation
Under the current tax system, there is no unilateral double tax relief. Foreign tax credit carry-forward or carry-backs do not exist.
Below is a summary of the available methods for various income tax streams based on domestic law.
| Royalty Copyright | ND |
| Capital Gains | ND |
| Dividends | ND |
| Interest | ND |
| Royalty Patent | ND |
| Sales | ND |
| Service Management | ND |
| Service Technical | ND |
| Royalty Trademark | ND |
The credit column shows the type of foreign tax credit granted when the receiving country receives a payment. Four abbreviations are used for the type of foreign tax credit available:
- NC means no credit but foreign withholding taxes can be deducted.
- OC means ordinary credit, i.e., credit for foreign withholding taxes (e.g., withholding taxes).
- IC means indirect credit, i.e., credit for underlying corporate taxes as well as foreign withholding taxes.
- ND means no credit and no deduction for any foreign withholding taxes incurred.