Personal scope

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....evasion with respect to taxes on income has entered into force on the 3rd June, 1997 after the notification by both the Contracting States to each other of the completion of the proceedings required by their laws for bringing into force of the said agreement in accordance with paragraph 1 of Article 29 of the said agreement; Now, therefore, in exercise of the powers conferred by section 90 of t....

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....ion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this agreement for the indirect benefit of residents of third States); Have agreed as follows:] ARTICLE 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States.     *************** NOTES:- 1.  ....