- 1. Where under any provision of this Convention any income is relieved from tax in a Contracting State and, under the domestic law in force in the other Contracting State, a person, in respect of that income, is subject to tax by reference to the amount thereof which is remitted to or received in that other State and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first-mentioned State shall apply only to so much of the income as is taxed in the other State. This provision shall not apply to income referred to in Articles 7 and 11.
- 2. Where under Article 14 gains may only be taxed in one of the Contracting States and under the domestic law in force in that State a person is subject to tax in respect of those gains by reference to the amount thereof which is remitted to or received in that State and not by reference to the full amount thereof, the relief to be allowed under that Article in the other Contracting State shall apply only to so much of the gains as are taxed in the first mentioned State.
- 3. Notwithstanding the provisions of sub-paragraph (b) of paragraph 1 of Article 2, for the purposes of the assessment in respect of the capital tax (l’impôt de solidarité sur la fortune) of an individual who is a resident of France and is a national of the United Kingdom without being a national of France, property situated outside France which he owns on 1st January in each of the five calendar years following that in which he became a resident of France shall not be included in the basis of assessment of the tax pertaining to each of those five years. If that person loses the status of resident of France for a period of at least three years, and then becomes a resident of France again, property situated outside France which he owns on 1st January in each of the five calendar years following that in which he became a resident of France again shall not be included in the basis of assessment of the tax pertaining to each of those five years.