(3) For the purposes of taxation on each side, income shall be considered to comprise the Company's total income minus the income falling to the other side. Half of the income shall fall to the German and half to the Austrian side. However, any excess in the payments made by the consumer of one side in pursuance of article 14 shall be regarded as income only in that consumer's State, and the additional tax liability so equalized shall be regarded as an operating expense only in that State.