Persons covered by tax treaties: residency governs applicability while fiscally transparent entities' income may be attributed for treaty purposes. Article 1 limits treaty coverage to persons resident in one or both Contracting States but allows denial of benefits under specified provisions; it treats income from fiscally transparent entities as resident income to the extent domestic law taxes it as such, permitting proportional attribution for passthrough arrangements and explicitly includes collective investment vehicles that are widely held, diversified and investor-protected.