a) for paragraph 1 not to apply to its Covered Tax Agreements on the basis that it intends to adopt a combination of a detailed limitation on benefits provision and either rules to address conduit

financing structures or a principal purpose test, thereby meeting the minimum standard for

preventing treaty abuse under the OECD/G20 BEPS package; in such cases, the Contracting

Jurisdictions shall endeavour to reach a mutually satisfactory solution which meets the

minimum standard;

b) for paragraph 1 (and paragraph 4, in the case of a Party that has chosen to apply that paragraph) not to apply to its Covered Tax Agreements that already contain provisions that deny all of the

benefits that would otherwise be provided under the Covered Tax Agreement where the

principal purpose or one of the principal purposes of any arrangement or transaction, or of any

person concerned with an arrangement or transaction, was to obtain those benefits;

c) for the Simplified Limitation on Benefits Provision not to apply to its Covered Tax Agreements that already contain the provisions described in paragraph 14.

16. Except where the Simplified Limitation on Benefits Provision applies with respect to the granting of benefits under a Covered Tax Agreement by one or more Parties pursuant to paragraph 7, a Party that chooses

pursuant to paragraph 6 to apply the Simplified Limitation on Benefits Provision may reserve the right for

the entirety of this Article not to apply with respect to its Covered Tax Agreements for which one or more

of the other Contracting Jurisdictions has not chosen to apply the Simplified Limitation on Benefits

Provision. In such cases, the Contracting Jurisdictions shall endeavour to reach a mutually satisfactory

solution which meets the minimum standard for preventing treaty abuse under the OECD/G20 BEPS

package.

17. a) Each Party that has not made the reservation described in subparagraph a) of paragraph 15 shall notify the Depositary of whether each of its Covered Tax Agreements that is not subject to a

reservation described in subparagraph b) of paragraph 15 contains a provision described in

paragraph 2, and if so, the article and paragraph number of each such provision. 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 (and where

applicable, paragraph 4). In other cases, paragraph 1 (and where applicable, paragraph 4) shall

supersede the provisions of the Covered Tax Agreement only to the extent that those provisions

are incompatible with paragraph 1 (and where applicable, paragraph 4). A Party making a

notification under this subparagraph may also include a statement that while such Party accepts

the application of paragraph 1 alone as an interim measure, it intends where possible to adopt a

limitation on benefits provision, in addition to or in replacement of paragraph 1, through

bilateral negotiation.

b) Each Party that chooses to apply paragraph 4 shall notify the Depositary of its choice. Paragraph 4 shall apply to a Covered Tax Agreement only where all Contracting Jurisdictions have made

such a notification.

c) Each Party that chooses to apply the Simplified Limitation on Benefits Provision pursuant to paragraph 6 shall notify the Depositary of its choice. Unless such Party has made the reservation

described in subparagraph c) of paragraph 15, such notification shall also include the list of its

Covered Tax Agreements which contain a provision described in paragraph 14, as well as the

article and paragraph number of each such provision.

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