Double taxation avoidance: treaty applies to residents and limits treatment of fiscally transparent entities, affecting tax attribution.

The Agreement applies to persons resident in one or both Contracting States and directs implementation in India for income arising on or after the fiscal year following the calendar year in which the Agreement entered into force. Income from an entity or arrangement treated as wholly fiscally transparent is regarded as income of a resident of a Contracting State only to the extent it is treated as resident income for taxation by that State.

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