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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 1

Persons Covered

(1) This Convention shall apply to persons who are residents of one or both of the Contracting States.

(2) For the purposes of this Convention, income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either Contracting State shall be considered to be income of a resident of a Contracting State but only to the extent that the income is treated, for purposes of taxation by that Contracting State, as the income of a resident of that Contracting State. In no case shall the provisions of this paragraph be construed to affect a Contracting State's right to tax the residents of that Contracting State.

(3) Provisions of this Convention that require a Contracting State to exempt from income tax or provide a deduction or credit equal to the income tax paid with respect to income derived by a resident of that Contracting State which may be taxed in the other Contracting State according to the provisions of this Convention shall not apply to the extent that such provisions allow taxation by that other Contracting State solely because the income is also income derived by a resident of that other Contracting State.

(4) This Convention shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph (3) of Article 7 (Business Profits), paragraph (2) of Article 9 (Associated Enterprises) and Articles 19 (Government Service), 20 (Professors, Teachers and Researchers), 21 (Students) 23 (Elimination of Double Taxation), 24 (Non-discrimination), 25 (Mutual Agreement Procedure) and 27 (Members of Diplomatic Missions and Consular Posts).