with references to “30 days after the date of receipt by the Depositary of the latest notification by each Contracting Jurisdiction making the reservation described in paragraph 7 of Article 35

(Entry into Effect) that it has completed its internal procedures for the entry into effect of the

provisions of Part VI (Arbitration) with respect to that specific Covered Tax Agreement”.

b) A Party making a reservation in accordance with subparagraph a) shall notify the confirmation of the completion of its internal procedures simultaneously to the Depositary and the other

Contracting Jurisdiction(s).

c) If one or more Contracting Jurisdictions to a Covered Tax Agreement makes a reservation under this paragraph, the date of entry into effect of the provisions of the Convention, of the

withdrawal or replacement of a reservation, of an additional notification with respect to that

Covered Tax Agreement, or of Part VI (Arbitration) shall be governed by this paragraph for all

Contracting Jurisdictions to the Covered Tax Agreement.

Article 36 – Entry into Effect of Part VI

1. Notwithstanding paragraph 9 of Article 28 (Reservations), paragraph 6 of Article 29 (Notifications), and paragraphs 1 through 6 of Article 35 (Entry into Effect), with respect to two Contracting Jurisdictions to

a Covered Tax Agreement, the provisions of Part VI (Arbitration) shall have effect:

a) with respect to cases presented to the competent authority of a Contracting Jurisdiction (as described in subparagraph a) of paragraph 1 of Article 19 (Mandatory Binding Arbitration)), on

or after the later 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 cases presented to the competent authority of a Contracting Jurisdiction prior to the later of the dates on which this Convention enters into force for each of the Contracting

Jurisdictions to the Covered Tax Agreement, on the date when both Contracting Jurisdictions

have notified the Depositary that they have reached mutual agreement pursuant to paragraph 10

of Article 19 (Mandatory Binding Arbitration), along with information regarding the date or

dates on which such cases shall be considered to have been presented to the competent authority

of a Contracting Jurisdiction (as described in subparagraph a) of paragraph 1 of Article 19

(Mandatory Binding Arbitration)) according to the terms of that mutual agreement.

2. A Party may reserve the right for Part VI (Arbitration) to apply to a case presented to the competent authority of a Contracting Jurisdiction prior to the later of the dates on which this Convention enters into

force for each of the Contracting Jurisdictions to the Covered Tax Agreement only to the extent that the

competent authorities of both Contracting Jurisdictions agree that it will apply to that specific case.

3. In the case of 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 references in paragraphs 1 and 2 of this Article to “the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered

Tax Agreement” shall be replaced with references to “the date of the communication by the Depositary of the notification of the extension of the list of agreements”.

4. A withdrawal or replacement of a reservation made under paragraph 4 of Article 26 (Compatibility) pursuant to paragraph 9 of Article 28 (Reservations), or the withdrawal of an objection to a reservation made

under paragraph 2 of Article 28 (Reservations) which results in the application of Part VI

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