The decree concerns the application of the new Para. 4 to Art. 24 (Basis of taxation) which was added by the protocol to the treaty of 8 March 2004 and entered into force on 1 January 2005. Art. 24(4) of the treaty provides that in the case of an item of income, profit or gain derived through a person that is fiscally transparent under the laws of either state, such item shall be considered to be …