Residence-based scope: applies to residents of contracting states, covers fiscally transparent entities' income, and lists specified exceptions. The Convention applies to persons who are residents of one or both Contracting States. Income from entities or arrangements treated as fiscally transparent under a Contracting State's law is treated as income of that State's resident only to the extent it is taxable as such. The Convention does not alter a State's taxation of its residents except for benefits expressly provided by specified treaty articles, and Contracting States may address collective investment vehicles differently depending on domestic and policy considerations.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Residence-based scope: applies to residents of contracting states, covers fiscally transparent entities' income, and lists specified exceptions.
The Convention applies to persons who are residents of one or both Contracting States. Income from entities or arrangements treated as fiscally transparent under a Contracting State's law is treated as income of that State's resident only to the extent it is taxable as such. The Convention does not alter a State's taxation of its residents except for benefits expressly provided by specified treaty articles, and Contracting States may address collective investment vehicles differently depending on domestic and policy considerations.
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