*International taxation* *Model Tax Conventions Series* *KP 2 (08-07-2020)*

# Scope of the convention (1) Persons covered (2) Taxes covered

# *Persons covered*-

*Resident of Contracting State (CS)- For application of treaty, a person has to be a resident of one or both of the CSs.

*Fiscally transparent entity*-Income derived by or through a fiscally transparent entity under the tax law of either CS to be considered to be income of a resident of a CS, to the extent such income is treated, for the purposes of taxation by that State, as the income of a resident of that State.

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