Article 3(1) of MLI – Taxation of income derived by or through fiscally transparent entities

 

Article 3(1) is the primary provision of Article 3. It reflects BEPS Action Plan 2 measure that addresses income earned through fiscally transparent entities. To understand this provision’s genesis, we need to look into the issues of fiscally transparent entities while availing the treaty benefits. Whether treaty applies to a Fiscally transparent entity? Article 1 … Continue reading Article 3(1) of MLI – Taxation of income derived by or through fiscally transparent entities