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This Convention shall apply to persons who are residents of one or both of the Contracting States.
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The following paragraph 1 of Article 3 of the MLI applies and supersedes the provisions of this Convention:
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Article 3 of the MLI — transparent entities.
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For the purposes of [this Convention], income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either [Contracting State] shall be considered to be income of a resident of a [Contracting State] but only to the extent that the income is treated, for purposes of taxation by that [Contracting State], as the income of a resident of that [Contracting State].
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The following paragraph 1 of Article 11 of the MLI applies and supersedes the provisions of this Convention:
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Article 11 of the MLI — application of tax agreements to restrict a party’s right to tax its own residents [This Convention] shall not affect the taxation by a [Contracting State] of its residents, except with respect to the benefits granted under [paragraph (2) of Article 9, paragraph (2) of Article 17 or Articles 18, 19, 20, 22, 24, 25, or 27] of [this Convention].