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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
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[The 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, or Articles 18, 19, 21, 23, 24 or 26 of [the Convention].