Article 35 Entry into Effect

1.

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 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.

3.

4.

5.

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.

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’;

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 this Convention with respect to that specific Covered Tax Agreement’;

iii)

the references in subparagraph a) of paragraph 9 of Article 28 (Reservations) to ‘on the date of the communication by the Depositary of the notification of withdrawal or replacement of the reservation’; and

iv)

the reference in subparagraph b) of paragraph 9 of Article 28 (Reservations) to ‘on the latest of the dates on which the Convention enters into force for those Contracting Jurisdictions’;

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 withdrawal or replacement of the reservation with respect to that specific Covered Tax Agreement’;

v)

the references in subparagraph a) of paragraph 6 of Article 29 (Notifications) to ‘on the date of the communication by the Depositary of the additional notification’; and

vi)

the reference in subparagraph b) of paragraph 6 of Article 29 (Notifications) to ‘on the latest of the dates on which the Convention enters into force for those Contracting Jurisdictions’;

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 additional notification with respect to that specific Covered Tax Agreement’;

vii)

the references in paragraphs 1 and 2 of Article 36 (Entry into Effect of Part VI) to ‘the later of the dates on which this Convention enters into force for each of the Contracting Jurisdictions to the Covered Tax Agreement’;

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 this Convention with respect to that specific Covered Tax Agreement’; and

viii)

the reference in paragraph 3 of Article 36 (Entry into Effect of Part VI) to ‘the date of the communication by the Depositary of the notification of the extension of the list of agreements’;

ix)

the references in paragraph 4 of Article 36 (Entry into Effect of Part VI) to ‘the date of the communication by the Depositary of the notification of withdrawal of the reservation’, ‘the date of the communication by the Depositary of the notification of replacement of the reservation’ and ‘the date of the communication by the Depositary of the notification of withdrawal of the objection to the reservation’; and

x)

the reference in paragraph 5 of Article 36 (Entry into Effect of Part VI) to ‘the date of the communication by the Depositary of the additional notification’;

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.