f) for paragraph 2 not to apply to its Covered Tax Agreements;

g) for paragraph 1 to apply only to its Covered Tax Agreements that already contain a provision described in paragraph 4 which identifies in detail the treatment of specific fact patterns and

types of entities or arrangements.

6. Each Party that has not made a reservation described in subparagraph a) or b) of paragraph 5 shall notify the Depositary of whether each of its Covered Tax Agreements contains a provision described in

paragraph 4 that is not subject to a reservation under subparagraphs c) through e) of paragraph 5, and if so,

the article and paragraph number of each such provision. In the case of a Party that has made the reservation

described in subparagraph g) of paragraph 5, the notification pursuant to the preceding sentence shall be

limited to Covered Tax Agreements that are subject to that reservation. Where all Contracting Jurisdictions

have made such a notification with respect to a provision of a Covered Tax Agreement, that provision shall

be replaced by the provisions of paragraph 1 (as it may be modified by paragraph 3) to the extent provided

in paragraph 4. In other cases, paragraph 1 (as it may be modified by paragraph 3) shall supersede the

provisions of the Covered Tax Agreement only to the extent that those provisions are incompatible with

paragraph 1 (as it may be modified by paragraph 3).

Article 4 – Dual Resident Entities

1. Where by reason of the provisions of a Covered Tax Agreement a person other than an individual is a resident of more than one Contracting Jurisdiction, the competent authorities of the Contracting Jurisdictions

shall endeavour to determine by mutual agreement the Contracting Jurisdiction of which such person shall

be deemed to be a resident for the purposes of the Covered Tax Agreement, having regard to its place of

effective management, the place where it is incorporated or otherwise constituted and any other relevant

factors. In the absence of such agreement, such person shall not be entitled to any relief or exemption from

tax provided by the Covered Tax Agreement except to the extent and in such manner as may be agreed upon

by the competent authorities of the Contracting Jurisdictions.

2. Paragraph 1 shall apply in place of or in the absence of provisions of a Covered Tax Agreement that provide rules for determining whether a person other than an individual shall be treated as a resident of one

of the Contracting Jurisdictions in cases in which that person would otherwise be treated as a resident of

more than one Contracting Jurisdiction. Paragraph 1 shall not apply, however, to provisions of a Covered

Tax Agreement specifically addressing the residence of companies participating in dual-listed company

arrangements.

3. A Party may reserve the right:

a) for the entirety of this Article not to apply to its Covered Tax Agreements;

b) for the entirety of this Article not to apply to its Covered Tax Agreements that already address cases where a person other than an individual is a resident of more than one Contracting

Jurisdiction by requiring the competent authorities of the Contracting Jurisdictions to endeavour

to reach mutual agreement on a single Contracting Jurisdiction of residence;

c) for the entirety of this Article not to apply to its Covered Tax Agreements that already address cases where a person other than an individual is a resident of more than one Contracting

Jurisdiction by denying treaty benefits without requiring the competent authorities of the

Contracting Jurisdictions to endeavour to reach mutual agreement on a single Contracting

Jurisdiction of residence;

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