Article 1 - Person Covered

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the Article 4. * It does not means a person have resident of contracting state then he is entitled to the benefit of the convention, it may be denied by under various provisions of the Model Convention. Income drive by an entity treated as wholly or partly fiscally transparent * For the purposes of this Convention, income derived by or through an entity or arrangement that is treated as whol....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the other one is resident of a country with which states A and B do not have a treaty. The paragraph provides that in such case, half of the interest shall be considered, for the purpose of Article 11, to be income of a resident of State B. Exception of the benefit granted to a resident * This Convention shall not affect the taxation, by a Contracting State, of its residents except with respe....