Artikel I

1. It is understood that the OECD Commentary is an important guideline when interpreting the provisions of this Agreement that are the same or substantially the same as the corresponding provisions of the OECD Model Convention on income and on capital at the time of signing as well as subsequent clarifying modifications of the OECD Commentary on these provisions. The understanding in the preceding sentence shall not apply with respect to any contrary interpretation agreed to in this Protocol, to contrary interpretation agreed to by the competent authorities after the entry into force of the Agreement or to reservations or observations to the OECD Model Tax Convention or OECD Commentary by either Contracting Party.
2. For the purposes of applying this Agreement an item of income, profit or gain derived through a person that is fiscally transparent under the laws of either Contracting Party, shall be considered to be derived by a resident of a Contracting Party to the extent that the item is treated for the purposes of the taxation law of such Contracting Party as the income, profit or gain of that resident.