Article 2 Taxes covered

1.

a)

to the following taxes:

i.

taxes on income or profits,

ii.

taxes on capital gains which are imposed separately from the tax on income or profits,

iii.

taxes on net wealth,

imposed on behalf of a Party; and

b)

to the following taxes:

i.

taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party,

ii.

compulsory social security contributions payable to general government or to social security institutions established under public law, and

iii.

taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

A.

estate, inheritance or gift taxes,

B.

taxes on immovable property,

C.

general consumption taxes, such as value-added or sales taxes,

D.

specific taxes on goods and services such as excise taxes,

E.

taxes on the use or ownership of motor vehicles,

F.

taxes on the use or ownership of movable property other than motor vehicles,

G.

any other taxes;

iv.

taxes in categories referred to in sub-paragraph (iii) above which are imposed on behalf of political sub-divisions or local authorities of a Party.

2.

3.

4.