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3.8. Specific (Deemed) Residence Rules for Partnerships, Hybrid and Specific Other Entities

Partnerships and commercial associations are considered tax resident persons pursuant to the ordinary criteria (see above).

Collective investment vehicles (e.g. investment funds) are considered tax resident persons pursuant to the ordinary criteria (see above) provided they are established as legal entities. Such collective investment vehicles should be regarded as resident persons also for tax treaty purposes. Mutual funds established as pools of assets (i.e. not having a status of legal entity) are not considered to be tax residents and are also not entitled to treaty benefits.