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<h1>Tax Treaty Clarifies Residency Status and Cross-Border Taxation for Entities with Complex Fiscal Transparency Rules</h1> The the scope of a Double Tax Avoidance Agreement (DTAA) based on the OECD Model. It applies to residents of contracting states, including entities with fiscal transparency. The convention does not fully impact taxation of residents, with specific exceptions for certain articles related to business profits, associated enterprises, income, capital, non-discrimination, mutual agreement procedures, and diplomatic privileges.