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- (1) Where under any provision of this Convention any income is relieved from tax in a Contracting State and, under the 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 Contracting State and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first mentioned Contracting State shall apply only to so much of the income as is taxed in the other Contracting State.
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- (2) The provisions of this Convention shall not apply to persons entitled to any special tax benefit under:
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- (a) a law of either one of the Contracting States which has been identified in an Exchange of Notes between the Contracting States; or
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- (b) any substantially similar law subsequently enacted.