Common use of PERSONS COVERED Clause in Contracts

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 of Article 7, paragraph 2 of Article 9 and Articles 18, 19, 22, 23, 24 and 27.

PERSONS COVERED. 1. This Agreement Convention shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this AgreementConvention, 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. 3. This Agreement Convention shall not affect the taxation, taxation by a Contracting State, State of its residents except with respect to the benefits granted under paragraph 3 of Article 7, paragraph paragraphs 2 and 3 of Article 9 9, and Articles 18, 19, 22, 23, 24 24, 25 and 2728.

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 2 of Article 79, paragraph 2 of Article 9 18, and Articles 18, 19, 2220, 21, 23, 24 26, 27 and 2729.

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 of Article 7, paragraph 2 of Article 9 and Articles 1819, 1920, 22, 2324, 24 25 and 27.

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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 the purposes of taxation by that Contracting State, as the income of a resident of that Contracting State. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 of Article 7, paragraph 2 of Article 9 and Articles 18, 19, 21, 22, 23, 24 23 and 2726.

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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 the pur‐ poses of taxation by that Contracting State, as the income of a resident of that Contracting State. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents resi‐ dents except with respect to the benefits granted under paragraph 3 of Article 7, paragraph 2 of Article 9 and Articles 18, 19, 21, 22, 23, 24 23 and 2726.

PERSONS COVERED. (1. ) This Agreement shall apply to persons who are residents of one or both of the Contracting Statesterritories. (2. ) For the purposes of this Agreement, income or gains 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 territory shall be considered to be income or gains of a resident of a Contracting State territory but only to the extent that the income or gain is treated, for purposes of taxation by that Contracting Stateterritory, as the income or gain of a resident of that Contracting Stateterritory. (3. ) This Agreement shall not affect the taxation, by a Contracting Stateterritory, of its residents except with respect to the benefits granted under paragraph 3 (3) of Article 7, paragraph 2 (2) of Article 9 and Articles 18, 19, 22, 23, 24 and 27.

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 of Article 7, paragraph 2 of Article 9 and Articles 1819, 1920, 22, 23, 24 and 27.

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 2 of Article 79, paragraph 2 of Article 9 18, and Articles 18, 19, 2220, 21, 23, 24 25, 26 and 2728.

PERSONS COVERED. 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this Agreement, 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. 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 2 of Article 79, paragraph 2 of Article 9 18, and Articles 18, 19, 2220, 23, 24 24, 25 and 27.