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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

These Provisions will apply to persons who are residents of one or both of the territories referred to in sub-paragraphs (a) and (b) of paragraph (1) of Article 2.