To the extent that a tax-sparing provision within a Convention deems an amount to have been paid to the government of a foreign country, the taxes spared will qualify as a "non-business income tax."
As s. 20(12) provides for a deduction from income and not from tax, Conventions which provide for "a deduction from the tax on the income of that person" for taxes that have been spared will not render s. 20(12) applicable.
