8. Each Party that has not made a reservation described in subparagraph a) or c) of paragraph 6 and does not choose to apply an Option under paragraph 1 shall notify the Depositary of whether each of its Covered

Tax Agreements contains a provision described in subparagraph b) of paragraph 5, as well as the article and

paragraph number of each such provision. Paragraph 4 shall apply with respect to a provision of a Covered

Tax Agreement only where all Contracting Jurisdictions have made a notification with respect to that

provision under this paragraph or paragraph 7.

Article 14 – Splitting-up of Contracts

1. For the sole purpose of determining whether the period (or periods) referred to in a provision of a Covered Tax Agreement that stipulates a period (or periods) of time after which specific projects or activities

shall constitute a permanent establishment has been exceeded:

a) where an enterprise of a Contracting Jurisdiction carries on activities in the other Contracting Jurisdiction at a place that constitutes a building site, construction project, installation project

or other specific project identified in the relevant provision of the Covered Tax Agreement, or

carries on supervisory or consultancy activities in connection with such a place, in the case of a

provision of a Covered Tax Agreement that refers to such activities, and these activities are

carried on during one or more periods of time that, in the aggregate, exceed 30 days without

exceeding the period or periods referred to in the relevant provision of the Covered Tax

Agreement; and

b) where connected activities are carried on in that other Contracting Jurisdiction at (or, where the relevant provision of the Covered Tax Agreement applies to supervisory or consultancy

activities, in connection with) the same building site, construction or installation project, or

other place identified in the relevant provision of the Covered Tax Agreement during different

periods of time, each exceeding 30 days, by one or more enterprises closely related to the first-

mentioned enterprise,

these different periods of time shall be added to the aggregate period of time during which the first-

mentioned enterprise has carried on activities at that building site, construction or installation project, or

other place identified in the relevant provision of the Covered Tax Agreement.

2. Paragraph 1 shall apply in place of or in the absence of provisions of a Covered Tax Agreement to the extent that such provisions address the division of contracts into multiple parts to avoid the application of a

time period or periods in relation to the existence of a permanent establishment for specific projects or

activities described in paragraph 1.

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 with respect to provisions of its Covered Tax Agreements relating to the exploration for or exploitation of natural resources.

4. Each Party that has not made a reservation described in subparagraph a) of paragraph 3 shall notify the Depositary of whether each of its Covered Tax Agreements contains a provision described in paragraph

2 that is not subject to a reservation under subparagraph b) of paragraph 3, 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

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