- 1
- It is understood that both Contracting States will follow the OECD Commentary when applying and interpreting the provisions of this Convention that are substantially the same as those in the OECD Model Convention.
- 2
- In the case of an item of income, profit or gain derived through a person that is fiscally transparent under the laws of either State, such item shall be considered to be derived by a resident of a State to the extent that the item is treated for the purposes of the taxation law of such State as the income, profit or gain of a resident.
