EN
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2. The competent authority shall endeavour, if the objection appears to it to be…
3. The competent authorities of the Contracting Jurisdictions shall endeavour to…
4. a) i) The first sentence of paragraph 1 shall apply in place of or in the absence…
ii) The second sentence of paragraph 1 shall apply in place of provisions of a Covered…
b) i) The first sentence of paragraph 2 shall apply in the absence of provisions…
ii) The second sentence of paragraph 2 shall apply in the absence of provisions of…
c) i) The first sentence of paragraph 3 shall apply in the absence of provisions…
ii) The second sentence of paragraph 3 shall apply in the absence of provisions of…
5. A Party may reserve the right:…
a) for the first sentence of paragraph 1 not to apply to its Covered Tax Agreements…
b) for the second sentence of paragraph 1 not to apply to its Covered Tax Agreements…
c) for the second sentence of paragraph 2 not to apply to its Covered Tax Agreements…
i) any agreement reached via the mutual agreement procedure shall be implemented…
ii) it intends to meet the minimum standard for improving dispute resolution under…
A) the Contracting Jurisdictions shall make no adjustment to the profits that are…
B) the Contracting Jurisdictions shall not include in the profits of an enterprise,…
6. a) Each Party that has not made a reservation described in subparagraph a) of…
b) Each Party that has not made the reservation described in subparagraph b) of paragraph…
i) the list of its Covered Tax Agreements which contain a provision that provides…
ii) the list of its Covered Tax Agreements which contain a provision that provides…
c) Each Party shall notify the Depositary of:…
i) the list of its Covered Tax Agreements which do not contain a provision described…
to a Covered Tax Agreement only where all Contracting Jurisdictions have made such…
ii) in the case of a Party that has not made the reservation described in subparagraph…
d) Each Party shall notify the Depositary of:…
i) the list of its Covered Tax Agreements which do not contain a provision described…
ii) the list of its Covered Tax Agreements which do not contain a provision described…
Article 17 – Corresponding Adjustments…
1. Where a Contracting Jurisdiction includes in the profits of an enterprise of that…
2. Paragraph 1 shall apply in place of or in the absence of a provision that requires…
3. A Party may reserve the right:…
a) for the entirety of this Article not to apply to its Covered Tax Agreements that…
b) for the entirety of this Article not to apply to its Covered Tax Agreements on…
i) it shall make the appropriate adjustment referred to in paragraph 1; or…
ii) its competent authority shall endeavour to resolve the case under the provisions…
c) in the case of a Party that has made a reservation under clause ii) of subparagraph…
4. Each Party that has not made a reservation described in paragraph 3 shall notify…
