PART VII.

FINAL PROVISIONS

Article 27 – Signature and Ratification, Acceptance or Approval

1. As of 31 December 2016, this Convention shall be open for signature by:

a) all States;

b) Guernsey (the United Kingdom of Great Britain and Northern Ireland); Isle of Man (the United Kingdom of Great Britain and Northern Ireland); Jersey (the United Kingdom of Great Britain

and Northern Ireland); and

c) any other jurisdiction authorised to become a Party by means of a decision by consensus of the Parties and Signatories.

2. This Convention is subject to ratification, acceptance or approval.

Article 28 – Reservations

1. Subject to paragraph 2, no reservations may be made to this Convention except those expressly permitted by:

a) Paragraph 5 of Article 3 (Transparent Entities);

b) Paragraph 3 of Article 4 (Dual Resident Entities);

c) Paragraphs 8 and 9 of Article 5 (Application of Methods for Elimination of Double Taxation);

d) Paragraph 4 of Article 6 (Purpose of a Covered Tax Agreement);

e) Paragraphs 15 and 16 of Article 7 (Prevention of Treaty Abuse);

f) Paragraph 3 of Article 8 (Dividend Transfer Transactions);

g) Paragraph 6 of Article 9 (Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property);

h) Paragraph 5 of Article 10 (Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions);

i) Paragraph 3 of Article 11 (Application of Tax Agreements to Restrict a Party’s Right to Tax its Own Residents);

j) Paragraph 4 of Article 12 (Artificial Avoidance of Permanent Establishment Status through Commissionnaire Arrangements and Similar Strategies);

k) Paragraph 6 of Article 13 (Artificial Avoidance of Permanent Establishment Status through the Specific Activity Exemptions);

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