https://www.taxtmi.com/acts?id=4496 Article 1 applies the Agreement to persons who are residents of one or both Contracting States. Income of entities or arrangements treated as wholly fiscally transparent is considered income of a resident only to the extent that it is treated as such for taxation by that State. The Agreement does not otherwise affect a State's taxation of its residents except concerning specified treaty benefits. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 08 Nov 2024 15:17:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4496 Article 1 applies the Agreement to persons who are residents of one or both Contracting States. Income of entities or arrangements treated as wholly fiscally transparent is considered income of a resident only to the extent that it is treated as such for taxation by that State. The Agreement does not otherwise affect a State's taxation of its residents except concerning specified treaty benefits. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4496