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Article 51 Exemption from Taxation

1. The Bank, its assets, property, income and its operations and transactions pursuant to this Agreement,

shall be exempt from all taxation and from all customs duties. The Bank shall also be exempt from any obligation

for the payment, withholding or collection of any tax or duty.

2. No tax of any kind shall be levied on or in respect of salaries, emoluments and expenses, as the case may

be, paid by the Bank to Directors, Alternate Directors, the President, Vice-Presidents and other officers or

employees of the Bank, including experts and consultants performing missions or services for the Bank, except

where a member deposits with its instrument of ratification, acceptance, or approval a declaration that such

member retains for itself and its political subdivisions the right to tax salaries, and emoluments , as the case may

be, paid by the Bank to citizens or nationals of such member.

3. No tax of any kind shall be levied on any obligation or security issued by the Bank, including any dividend

or interest thereon, by whomsoever held:

(i) which discriminates against such obligation or security solely because it is issued by the Bank; or

(ii) if the sole jurisdictional basis for such taxation is the place or currency in which it is issued, made payable

or paid, or the location of any office or place of business maintained by the Bank.

4. No tax of any kind shall be levied on any obligation or security guaranteed by the Bank, including any

dividend or interest thereon, by whomsoever held:

(i) which discriminates against such obligation or security solely because it is guaranteed by the Bank; or

(ii) if the sole jurisdictional basis for such taxation is the location of any office or place of business maintained

by the Bank.

Article 52 Waivers

1. The Bank at its discretion may waive any of the privileges, immunities and exemptions conferred under

this Chapter in any case or instance, in such manner and upon such conditions as it may determine to be

appropriate in the best interests of the Bank.

CHAPTER X

AMENDMENT, INTERPRETATION AND ARBITRATION

Article 53 Amendments

1. This Agreement may be amended only by a resolution of the Board of Governors approved by a Super

Majority vote as provided in Article 28.

2. Notwithstanding the provisions of paragraph 1 of this Article, the unanimous agreement of the Board of

Governors shall be required for the approval of any amendment modifying:

(i) the right to withdraw from the Bank;

(ii) the limitations on liability provided in paragraphs 3 and 4 of Article 7; and

(iii) the rights pertaining to purchase of capital stock provided in paragraph 4 of Article 5.

3. Any proposal to amend this Agreement, whether emanating from a member or the Board of Directors, shall

be communicated to the Chairman of the Board of Governors, who shall bring the proposal before the Board of

Governors. When an amendment has been adopted, the Bank shall so certify in an official communication

addressed to all members. Amendments shall enter into force for all members three (3) months after the date of

the official communication unless the Board of Governors specifies therein a different period.

Article 54 Interpretation

1. Any question of interpretation or application of the provisions of this Agreement arising between any

member and the Bank, or between two or more members of the Bank, shall be submitted to the Board of Directors

for decision. If there is no Director of its nationality on that Board, a member particularly affected by the question

under consideration shall be entitled to direct representation in the Board of Directors during such consideration;

the representative of such member shall, however, have no vote. Such right of representation shall be regulated

by the Board of Governors.