AGREEMENT BETWEEN

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.