Tax residency governs treaty coverage and treats fiscally transparent entities' income as resident income for treaty purposes. The Agreement applies to persons who are residents of one or both Contracting States and treats income derived by or through entities or arrangements that are fiscally transparent as income of a resident where that income is treated for domestic taxation as the resident's income. The notification gives domestic effect to the Agreement and Protocol and specifies their application to fiscal years beginning on or after the first April following entry into force.