begins on or after the latest of the dates on which this Convention enters into force for each of

the Contracting Jurisdictions to the Covered Tax Agreement; and

b) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after the expiration of a period of six calendar months

(or a shorter period, if all Contracting Jurisdictions notify the Depositary that they intend to

apply such shorter period) from the latest of the dates on which this Convention enters into force

for each of the Contracting Jurisdictions to the Covered Tax Agreement.

2. Solely for the purpose of its own application of subparagraph a) of paragraph 1 and subparagraph a) of paragraph 5, a Party may choose to substitute “taxable period” for “calendar year”, and shall notify the Depositary accordingly.

3. Solely for the purpose of its own application of subparagraph b) of paragraph 1 and subparagraph b) of paragraph 5, a Party may choose to replace the reference to “taxable periods beginning on or after the expiration of a period” with a reference to “taxable periods beginning on or after 1 January of the next year beginning on or after the expiration of a period”, and shall notify the Depositary accordingly.

4. Notwithstanding the preceding provisions of this Article, Article 16 (Mutual Agreement Procedure) shall have effect with respect to a Covered Tax Agreement for a case presented to the competent authority

of a Contracting Jurisdiction on or after the latest of the dates on which this Convention enters into force for

each of the Contracting Jurisdictions to the Covered Tax Agreement, except for cases that were not eligible

to be presented as of that date under the Covered Tax Agreement prior to its modification by the Convention,

without regard to the taxable period to which the case relates.

5. For a new Covered Tax Agreement resulting from an extension pursuant to paragraph 5 of Article 29 (Notifications) of the list of agreements notified under clause ii) of subparagraph a) of paragraph 1 of Article

2 (Interpretation of Terms), the provisions of this Convention shall have effect in each Contracting

Jurisdiction:

a) with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next calendar year that

begins on or after 30 days after the date of the communication by the Depositary of the

notification of the extension of the list of agreements; and

b) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after the expiration of a period of nine calendar

months (or a shorter period, if all Contracting Jurisdictions notify the Depositary that they intend

to apply such shorter period) from the date of the communication by the Depositary of the

notification of the extension of the list of agreements.

6. A Party may reserve the right for paragraph 4 not to apply with respect to its Covered Tax Agreements.

7. a) A Party may reserve the right to replace:

i) the references in paragraphs 1 and 4 to “the latest of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax

Agreement”; and

ii) the references in paragraph 5 to “the date of the communication by the Depositary of the notification of the extension of the list of agreements”;

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