МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 23
                    Elimination of double taxation

     1.  In the case of Venezuela, double taxation shall be eliminated
as follows:
     a)  where  a  resident  of  Venezuela  derives  income, which, in
accordance  with  the  provisions  of  this Convention may be taxed in
Russia,  Venezuela shall allow as a tax credit from the Venezuelan tax
on the income of that resident, an amount equal to the income tax paid
in Russia, according to the Venezuelan tax legislation;
     b) the tax credit allowed under subparagraph a) of this paragraph
shall  not  exceed that part of the Venezuelan income tax, as computed
before  the  deduction  is  given, which is attributable to the income
which may be taxed in Russia.
     2.  In  the  case  of  Russia,  double  taxation is eliminated as
follows:
     Where  a resident of Russia derives income or owns capital which,
in  accordance with the provisions of this Convention, may be taxed in
Venezuela,  the  amount  of  tax  on that income or capital payable in
Venezuela may be credited against the tax levied in Russia. The amount
of  credit,  however, shall not exceed the amount of the tax of Russia
on  that  income  or  capital computed in accordance with its taxation
laws and regulations.