General Scope

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tates), have agreed as follows: ARTICLE 1 GENERAL SCOPE 1. This Convention shall apply only to persons who are residents of one or both of the Contracting States, except as otherwise provided in this Convention. 2. This Convention shall not restrict in any manner any benefit now or hereafter accorded: (a) by the laws of either Contracting State; or (b) by any other agreement to which both Contracting States are parties. 3. (a) Notwithstanding the provisions of subparagraph (b) of paragraph 2 of this Article: (i) for purposes of paragraph 3 of Article XXII (Consultation) of the General Agreement on Trade in Services, the Contracting States agree that any question arising as to the interpretation or a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....pport), paragraph 3 of Article 18 (Pension Funds), and Articles 23 (Relief From Double Taxation), 24 (Non-Discrimination) and 25 (Mutual Agreement Procedure); and (b) the benefits conferred by a Contracting State under paragraph 1 of Article 18 (Pension Funds), and Articles 19 (Government Service), 20 (Students and Trainees) and 27 (Members of Diplomatic Missions and Consular Posts), upon individuals who are neither citizens of, nor have been admitted for permanent residence in, that Contracting State. 6. For the purposes of this Convention, an item of income, profit or gain derived by or through an entity that is treated as wholly or partly fiscally transparent under the taxation laws of either Contracting State shall be consid....