to a Covered Tax Agreement only where all Contracting Jurisdictions have made such a

notification with respect to that Covered Tax Agreement;

ii) in the case of a Party that has not made the reservation described in subparagraph c) of paragraph 5, the list of its Covered Tax Agreements which do not contain a provision

described in clause ii) of subparagraph b) of paragraph 4; the second sentence of

paragraph 2 shall apply to a Covered Tax Agreement only where all Contracting

Jurisdictions have made such a notification with respect to that Covered Tax Agreement.

d) Each Party shall notify the Depositary of:

i) the list of its Covered Tax Agreements which do not contain a provision described in clause i) of subparagraph c) of paragraph 4; the first sentence of paragraph 3 shall apply

to a Covered Tax Agreement only where all Contracting Jurisdictions have made such a

notification with respect to that Covered Tax Agreement;

ii) the list of its Covered Tax Agreements which do not contain a provision described in clause ii) of subparagraph c) of paragraph 4; the second sentence of paragraph 3 shall

apply to a Covered Tax Agreement only where all Contracting Jurisdictions have made

such a notification with respect to that Covered Tax Agreement.

Article 17 – Corresponding Adjustments

1. Where a Contracting Jurisdiction includes in the profits of an enterprise of that Contracting Jurisdiction — and taxes accordingly — profits on which an enterprise of the other Contracting Jurisdiction has been charged to tax in that other Contracting Jurisdiction and the profits so included are profits which would have

accrued to the enterprise of the first-mentioned Contracting Jurisdiction if the conditions made between the

two enterprises had been those which would have been made between independent enterprises, then that

other Contracting Jurisdiction shall make an appropriate adjustment to the amount of the tax charged therein

on those profits. In determining such adjustment, due regard shall be had to the other provisions of the

Covered Tax Agreement and the competent authorities of the Contracting Jurisdictions shall if necessary

consult each other.

2. Paragraph 1 shall apply in place of or in the absence of a provision that requires a Contracting Jurisdiction to make an appropriate adjustment to the amount of the tax charged therein on the profits of an

enterprise of that Contracting Jurisdiction where the other Contracting Jurisdiction includes those profits in

the profits of an enterprise of that other Contracting Jurisdiction and taxes those profits accordingly, and the

profits so included are profits which would have accrued to the enterprise of that other Contracting

Jurisdiction if the conditions made between the two enterprises had been those which would have been made

between independent enterprises.

3. A Party may reserve the right:

a) for the entirety of this Article not to apply to its Covered Tax Agreements that already contain a provision described in paragraph 2;

b) for the entirety of this Article not to apply to its Covered Tax Agreements on the basis that in the absence of a provision referred to in paragraph 2 in its Covered Tax Agreement:

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