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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 3: Tax Treatment of Income via Fiscally Transparent Entities Under Tax Treaty Measures</h1> Article 3 of the Convention to Implement Tax Treaty Measures addresses the treatment of income derived through entities considered fiscally transparent under the tax laws of either Contracting Jurisdiction. Such income is deemed to belong to a resident of the jurisdiction for tax purposes, only if the jurisdiction treats it as such. Provisions exempting or crediting income tax in one jurisdiction, due to taxation in another, do not apply if the taxation is based solely on residency. Contracting Parties can reserve rights to apply or not apply these rules to their agreements, with specific conditions for notification and replacement of existing provisions.
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