operations, had as one of its principal purposes the obtaining of benefits under the Covered Tax Agreement.

Before either granting or denying a request made under this paragraph by a resident of a Contracting

Jurisdiction, the competent authority of the other Contracting Jurisdiction to which the request has been made

shall consult with the competent authority of the first-mentioned Contracting Jurisdiction.

13. For the purposes of the Simplified Limitation on Benefits Provision:

a) the term “recognised stock exchange” means:

i) any stock exchange established and regulated as such under the laws of either Contracting Jurisdiction; and

ii) any other stock exchange agreed upon by the competent authorities of the Contracting Jurisdictions;

b) the term “principal class of shares” means the class or classes of shares of a company which represents the majority of the aggregate vote and value of the company or the class or classes

of beneficial interests of an entity which represents in the aggregate a majority of the aggregate

vote and value of the entity;

c) the term “equivalent beneficiary” means any person who would be entitled to benefits with respect to an item of income accorded by a Contracting Jurisdiction to a Covered Tax

Agreement under the domestic law of that Contracting Jurisdiction, the Covered Tax Agreement

or any other international instrument which are equivalent to, or more favourable than, benefits

to be accorded to that item of income under the Covered Tax Agreement; for the purposes of

determining whether a person is an equivalent beneficiary with respect to dividends, the person

shall be deemed to hold the same capital of the company paying the dividends as such capital

the company claiming the benefit with respect to the dividends holds;

d) with respect to entities that are not companies, the term “shares” means interests that are comparable to shares;

e) two persons shall be “connected persons” if one owns, directly or indirectly, at least 50 per cent of the beneficial interest in the other (or, in the case of a company, at least 50 per cent of

the aggregate vote and value of the company's shares) or another person owns, directly or

indirectly, at least 50 per cent of the beneficial interest (or, in the case of a company, at least 50

per cent of the aggregate vote and value of the company's shares) in each person; in any case, a

person shall be connected to another if, based on all the relevant facts and circumstances, one

has control of the other or both are under the control of the same person or persons.

14. The Simplified Limitation on Benefits Provision shall apply in place of or in the absence of provisions of a Covered Tax Agreement that would limit the benefits of the Covered Tax Agreement (or that would

limit benefits other than a benefit under the provisions of the Covered Tax Agreement relating to residence,

associated enterprises or non-discrimination or a benefit that is not restricted solely to residents of a

Contracting Jurisdiction) only to a resident that qualifies for such benefits by meeting one or more categorical

tests.

15. A Party may reserve the right:

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