e) Paragraphs 5 and 6 of Article 6 (Purpose of a Covered Tax Agreement);

f) Paragraph 17 of Article 7 (Prevention of Treaty Abuse);

g) Paragraph 4 of Article 8 (Dividend Transfer Transactions);

h) Paragraphs 7 and 8 of Article 9 (Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property);

i) Paragraph 6 of Article 10 (Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions);

j) Paragraph 4 of Article 11 (Application of Tax Agreements to Restrict a Party’s Right to Tax its Own Residents);

k) Paragraphs 5 and 6 of Article 12 (Artificial Avoidance of Permanent Establishment Status through Commissionnaire Arrangements and Similar Strategies);

l) Paragraphs 7 and 8 of Article 13 (Artificial Avoidance of Permanent Establishment Status through the Specific Activity Exemptions);

m) Paragraph 4 of Article 14 (Splitting-up of Contracts);

n) Paragraph 6 of Article 16 (Mutual Agreement Procedure);

o) Paragraph 4 of Article 17 (Corresponding Adjustments);

p) Article 18 (Choice to Apply Part VI);

q) Paragraph 4 of Article 23 (Type of Arbitration Process);

r) Paragraph 1 of Article 24 (Agreement on a Different Resolution);

s) Paragraph 1 of Article 26 (Compatibility); and

t) Paragraphs 1, 2, 3, 5 and 7 of Article 35 (Entry into Effect).

2. Notifications in respect of Covered Tax Agreements entered into by or on behalf of a jurisdiction or territory for whose international relations a Party is responsible, where that jurisdiction or territory is not a

Party to the Convention pursuant to subparagraph b) or c) of paragraph 1 of Article 27 (Signature and

Ratification, Acceptance or Approval), shall be made by the responsible Party and can be different from the

notifications made by that Party for its own Covered Tax Agreements.

3. If notifications are made at the time of signature, they shall be confirmed upon deposit of the instrument of ratification, acceptance or approval, unless the document containing the notifications explicitly

specifies that it is to be considered definitive, subject to the provisions of paragraphs 5 and 6 of this Article,

and paragraph 7 of Article 35 (Entry into Effect).

4. If notifications are not made at the time of signature, a provisional list of expected notifications shall be provided at that time.

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