S.L. 123.123 · Double Taxation Relief On Taxes On (S.L. 123.123)
S.L. 123.123 Art. 6that is fiscally to be for purposes of of a resident.
An item of income, profit or gain derived through an entity transparent under the Laws of either Contracting State shall be considered derived by a resident of a State to the extent that the item is treated the taxation law of such Contracting State as the income, profit or gain
Article 2 TAXES COVERED