(ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Portugal.

Such deduction in either case shall not, however, exceed that part of the

income tax or capital tax, as computed before the deduction is given,

which is attributable, as the case may be, to the income or the capital

which may be taxed in Portugal.

b) Where in accordance with any provisions of this Convention income de-

rived or capital owned by a resident of Georgia is exempt from tax in

Georgia, Georgia may nevertheless, in calculating the amount of tax on the

remaining income or capital of such resident, take into account the ex-

empted income or capital.

CHAPTER V

SPECIAL PROVISIONS

ARTICLE 24

NON-DISCRIMINATION

1. Nationals of a Contracting State shall not be subjected in the other Contracting

State to any taxation or any requirement connected therewith, which is other or more

burdensome than the taxation and connected requirements to which nationals of that

other State in the same circumstances, in particular with respect to residence, are or may

be subjected. This provision shall, notwithstanding the provisions of Article 1, also ap-

ply to persons who are not residents of one or both of the Contracting States.

2. Stateless persons who are residents of a Contracting State shall not be subjected

in either Contracting State to any taxation or any requirement connected therewith,

which is other or more burdensome than the taxation and connected requirements to

which nationals of the State concerned in the same circumstances, in particular with

respect to residence, are or may be subjected.

3. The taxation on a permanent establishment which an enterprise of a Contracting

State has in the other Contracting State shall not be less favourably levied in that other

State than the taxation levied on enterprises of that other State carrying on the same

activities. This provision shall not be construed as obliging a Contracting State to grant

to residents of the other Contracting State any personal allowances, reliefs and reduc-

tions for taxation purposes on account of civil status or family responsibilities which it

grants to its own residents.

4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article

11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid

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