Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 1
Persons Covered
(1) This Convention shall apply to persons who are residents of one or both of the Contracting States.
(2) This Convention shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph (2) of Article 9, paragraph (2) of Article 18 and Articles 19, 20, 23, 24, 25 and 28.