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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 State, as the income of a resident of that State.

(3) 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, paragraph (2) of Article 9 and Articles 18, 19, 22, 23, 24 and 26.