Article 1 - Persons Covered

Article 1 specifies that the India-Croatia DTAA applies to persons who are residents of one or both contracting States. "Person" includes individuals, companies, and any body of persons taxable as such under each State's domestic law. Treaty-shopping concerns (entities routed through a treaty country solely to obtain benefits) are addressed in Article 29 (Entitlement to Benefits) where applicable, supplementing the general anti-abuse principles in India's domestic law (GAAR under Section 415 of IT Act 2025).