ii) The second sentence of paragraph 2 shall apply in the absence of provisions of a Covered

Tax Agreement providing that any agreement reached shall be implemented

notwithstanding any time limits in the domestic law of the Contracting Jurisdictions.

c) i) The first sentence of paragraph 3 shall apply in the absence of provisions of a Covered Tax Agreement that provide that the competent authorities of the Contracting Jurisdictions

shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to

the interpretation or application of the Covered Tax Agreement.

ii) The second sentence of paragraph 3 shall apply in the absence of provisions of a Covered

Tax Agreement that provide that the competent authorities of the Contracting

Jurisdictions may also consult together for the elimination of double taxation in cases not

provided for in the Covered Tax Agreement.

5. A Party may reserve the right:

a) for the first sentence of paragraph 1 not to apply to its Covered Tax Agreements on the basis that it intends to meet the minimum standard for improving dispute resolution under the

OECD/G20 BEPS Package by ensuring that under each of its Covered Tax Agreements (other

than a Covered Tax Agreement that permits a person to present a case to the competent authority

of either Contracting Jurisdiction), where a person considers that the actions of one or both of

the Contracting Jurisdictions result or will result for that person in taxation not in accordance

with the provisions of the Covered Tax Agreement, irrespective of the remedies provided by

the domestic law of those Contracting Jurisdictions, that person may present the case to the

competent authority of the Contracting Jurisdiction of which the person is a resident or, if the

case presented by that person comes under a provision of a Covered Tax Agreement relating to

non-discrimination based on nationality, to that of the Contracting Jurisdiction of which that

person is a national; and the competent authority of that Contracting Jurisdiction will implement

a bilateral notification or consultation process with the competent authority of the other

Contracting Jurisdiction for cases in which the competent authority to which the mutual

agreement procedure case was presented does not consider the taxpayer’s objection to be justified;

b) for the second sentence of paragraph 1 not to apply to its Covered Tax Agreements that do not provide that the case referred to in the first sentence of paragraph 1 must be presented within a

specific time period on the basis that it intends to meet the minimum standard for improving

dispute resolution under the OECD/G20 BEPS package by ensuring that for the purposes of all

such Covered Tax Agreements the taxpayer referred to in paragraph 1 is allowed to present the

case within a period of at least three years from the first notification of the action resulting in

taxation not in accordance with the provisions of the Covered Tax Agreement;

c) for the second sentence of paragraph 2 not to apply to its Covered Tax Agreements on the basis that for the purposes of all of its Covered Tax Agreements:

i) any agreement reached via the mutual agreement procedure shall be implemented notwithstanding any time limits in the domestic laws of the Contracting Jurisdictions; or

ii) it intends to meet the minimum standard for improving dispute resolution under the OECD/G20 BEPS package by accepting, in its bilateral treaty negotiations, a treaty

provision providing that:

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