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Article II

Article II

 

1. The current wording of Article 1 (Personal scope) of the Convention shall become paragraph I of Article I.

2. A new paragraph 2 shall be added to Article 1 (Personal scope) of the Convention which shall read as follows:

"2. In the case of an item of income derived by or through a person that is fiscally transparent under the laws of either Contracting State, such item shall be considered to be derived by a resident of a Contracting State to the extent that the item is treated for the purposes of the taxation law of such State as the income of a resident."