https://www.taxtmi.com/acts?id=37364 Article 3 treats income derived by or through entities or arrangements regarded as fiscally transparent as income of a resident of a Contracting Jurisdiction, but only to the extent that jurisdiction taxes the income as the resident's. It limits treaty provisions that would require exemption, deduction or credit solely because the income may also be taxed by the other Contracting Jurisdiction. The Article permits specified reservations, requires Parties to notify the Depositary of pre-existing detailed treaty provisions, and provides that where all Parties notify, the treaty provision is replaced by paragraph 1; otherwise paragraph 1 supersedes only to the extent of incompatibility. en-us Tue, 20 Aug 2019 16:19:06 +0530 Mon, 10 Feb 2025 16:11:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37364 Article 3 treats income derived by or through entities or arrangements regarded as fiscally transparent as income of a resident of a Contracting Jurisdiction, but only to the extent that jurisdiction taxes the income as the resident's. It limits treaty provisions that would require exemption, deduction or credit solely because the income may also be taxed by the other Contracting Jurisdiction. The Article permits specified reservations, requires Parties to notify the Depositary of pre-existing detailed treaty provisions, and provides that where all Parties notify, the treaty provision is replaced by paragraph 1; otherwise paragraph 1 supersedes only to the extent of incompatibility. Act-Rules DTAA Tue, 20 Aug 2019 16:19:06 +0530 https://www.taxtmi.com/acts?id=37364