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<h1>Tax Convention Clarifies Income Attribution and Residency Status for Cross-Border Fiscal Transparency and Entity Taxation</h1> This provision defines the scope of a tax convention, applying to residents of contracting states. It addresses income derived through fiscally transparent entities, treating such income as belonging to a resident state for taxation purposes. The convention limits its impact on state taxation, with specific exceptions for certain articles. A provision regarding collective investment vehicles is noted, acknowledging potential variations in domestic tax rules and policy considerations.