Sayfa 363PART VII. FINAL PROVISIONS
Article 27 – Signature and Ratification, Acceptance or Approval…
1) As of 31 December 2016, this Convention shall be open for signature by:…
a) all States;…
b) Guernsey (the United Kingdom of Great Britain and Northern Ireland); Isle of Man…
c) any other jurisdiction authorised to become a Party by means of a decision by…
2) This Convention is subject to ratification, acceptance or approval.…
Article 28 – Reservations…
1. Subject to paragraph 2, no reservations may be made to this Convention except…
a) Paragraph 5 of Article 3 (Transparent Entities);…
b) Paragraph 3 of Article 4 (Dual Resident Entities);…
c) Paragraphs 8 and 9 of Article 5 (Application of Methods for Elimination of Double…
d) Paragraph 4 of Article 6 (Purpose of a Covered Tax Agreement);…
e) Paragraphs 15 and 16 of Article 7 (Prevention of Treaty Abuse);…
f) Paragraph 3 of Article 8 (Dividend Transfer Transactions);…
g) Paragraph 6 of Article 9 (Capital Gains from Alienation of Shares or Interests…
h) Paragraph 5 of Article 10 (Anti-abuse Rule for Permanent Establishments Situated…
i) Paragraph 3 of Article 11 (Application of Tax Agreements to Restrict a Party’s…
j) Paragraph 4 of Article 12 (Artificial Avoidance of Permanent Establishment Status…
k) Paragraph 6 of Article 13 (Artificial Avoidance of Permanent Establishment Status…
l) Paragraph 3 of Article 14 (Splitting-up of Contracts);…
m) Paragraph 2 of Article 15 (Definition of a Person Closely Related to an Enter…
n) Paragraph 5 of Article 16 (Mutual Agreement Procedure);…
o) Paragraph 3 of Article 17 (Corresponding Adjustments);…
p) Paragraphs 11 and 12 of Article 19 (Mandatory Binding Arbitration);…
q) Paragraphs 2, 3, 6, and 7 of Article 23 (Type of Arbitration Process);…
r) Paragraph 3 of Article 24 (Agreement on a Different Resolution);…
s) Paragraph 4 of Article 26 (Compatibility);…
t) Paragraphs 6 and 7 of Article 35 (Entry into Effect); and…
u) Paragraph 2 of Article 36 (Entry into Effect of Part VI).…
2. a) Notwithstanding paragraph 1, a Party that chooses under Article 18 (Choice…
b) Reservations made under subparagraph a) are subject to acceptance. A reservation…
3. Unless explicitly provided otherwise in the relevant provisions of this Convention,…
a) modify for the reserving Party in its relations with another Party the provisions…
b) modify those provisions to the same extent for the other Party in its relations…
4. Reservations applicable to Covered Tax Agreements entered into by or on behalf…
5. Reservations shall be made at the time of signature or when depositing the instrument…
6. If reservations are made at the time of signature, they shall be confirmed upon…
7. If reservations are not made at the time of signature, a provisional list of expected…
8. For reservations made pursuant to each of the following provisions, a list of…
a) Subparagraphs b), c), d), e) and g) of paragraph 5 of Article 3 (Transparent…
b) Subparagraphs b), c) and d) of paragraph 3 of Article 4 (Dual Resident Entiti…
c) Paragraphs 8 and 9 of Article 5 (Application of Methods for Elimination of Double…
d) Paragraph 4 of Article 6 (Purpose of a Covered Tax Agreement);…
e) Subparagraphs b) and c) of paragraph 15 of Article 7 (Prevention of Treaty Ab…
f) Clauses i), ii), and iii) of subparagraph b) of paragraph 3 of Article 8 (Dividend…
g) Subparagraphs d), e) and f) of paragraph 6 of Article 9 (Capital Gains from Alienation…
h) Subparagraphs b) and c) of paragraph 5 of Article 10 (Anti-abuse Rule for Permanent…
i) Subparagraph b) of paragraph 3 of Article 11 (Application of Tax Agreements to…
j) Subparagraph b) of paragraph 6 of Article 13 (Artificial Avoidance of Permanent…
k) Subparagraph b) of paragraph 3 of Article 14 (Splitting-up of Contracts);…
l) Subparagraph b) of paragraph 5 of Article 16 (Mutual Agreement Procedure);…
m) Subparagraph a) of paragraph 3 of Article 17 (Corresponding Adjustments);…
n) Paragraph 6 of Article 23 (Type of Arbitration Process); and…
o) Paragraph 4 of Article 26 (Compatibility).Sayfa 367…
The reservations described in subparagraphs a) through o) above shall not apply to…
9. Any Party which has made a reservation in accordance with paragraph 1 or 2 may…
a) with respect to a Covered Tax Agreement solely with States or jurisdictions that…
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