or a teacher, professor, lecturer, instructor, researcher or research scholar who meets the

conditions of the Covered Tax Agreement;

d) which require that Contracting Jurisdiction to provide a tax credit or tax exemption to residents of that Contracting Jurisdiction with respect to the income that the other Contracting Jurisdiction

may tax in accordance with the Covered Tax Agreement (including profits that are attributable

to a permanent establishment situated in that other Contracting Jurisdiction in accordance with

the Covered Tax Agreement);

e) which protect residents of that Contracting Jurisdiction against certain discriminatory taxation practices by that Contracting Jurisdiction;

f) which allow residents of that Contracting Jurisdiction to request that the competent authority of that or either Contracting Jurisdiction consider cases of taxation not in accordance with the

Covered Tax Agreement;

g) which may affect how that Contracting Jurisdiction taxes an individual who is a resident of that Contracting Jurisdiction when that individual is a member of a diplomatic mission, government

mission or consular post of the other Contracting Jurisdiction;

h) which provide that pensions or other payments made under the social security legislation of the other Contracting Jurisdiction shall be taxable only in that other Contracting Jurisdiction;

i) which provide that pensions and similar payments, annuities, alimony payments or other maintenance payments arising in the other Contracting Jurisdiction shall be taxable only in that

other Contracting Jurisdiction; or

j) which otherwise expressly limit a Contracting Jurisdiction’s right to tax its own residents or provide expressly that the Contracting Jurisdiction in which an item of income arises has the

exclusive right to tax that item of income.

2. Paragraph 1 shall apply in place of or in the absence of provisions of a Covered Tax Agreement stating that the Covered Tax Agreement would not affect the taxation by a Contracting Jurisdiction of its residents.

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 contain the provisions described in paragraph 2.

4. Each Party that has not made the reservation described in subparagraph a) or b) of paragraph 3 shall notify the Depositary of whether each of its Covered Tax Agreements 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. In other cases, paragraph 1 shall supersede the

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

paragraph 1.

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