Common use of General Exceptions Clause in Contracts

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health;; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII19, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other MembersParties; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the MemberParty's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberParty's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the MemberParty's tax base. Tax terms or concepts in subparagraph (d) of Article 12 and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Party taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5order;6 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVIII-4 (National Treatment), provided that the difference in treatment is aimed at ensuring the equitable or effective6 effective7 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 Parties; (e) inconsistent with Article [...], provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Party is bound. 6 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 7 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's Party’s territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberParty's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same personperson , in order to safeguard the MemberParty's tax base. Tax terms or concepts in paragraph (d) of Article [...] (General Exceptions) and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Party taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement Chapter shall be so construed as to prevent the adoption or enforcement by any Member either Party of measures: (a) necessary to protect public morals or to maintain public order;5order; Note: The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations of the Party which are not inconsistent with the provisions of this Agreement Chapter including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts;; and (iii) safety; (d) inconsistent with Article XVII47, provided that the difference in treatment is aimed at ensuring the equitable or effective6 effective imposition or collection of direct taxes in respect of services or service suppliers of the other MembersParty; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Note: Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's territory; orArea of the Party; (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; orArea of the Party; (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or; (iv) apply to consumers of services supplied in or from the territory Area of another Member the other Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; orArea of the Party; (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's Party’s tax base. Tax terms or concepts in this paragraph and this Note are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the law of the Party taking the measure. (e) inconsistent with Article II45, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement Chapter shall be construed to prevent the adoption or enforcement by any Member a Party of measures: (a) necessary to protect public morals or to maintain public order;5order;11 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement Chapter including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII3.5 (National Treatment), provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 effective12 11 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 12 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (ia) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's Party’s territory; or (iib) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's Party’s territory; or (iiic) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (ivd) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's Party’s territory; or (ve) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vif) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's Party’s tax base.. Tax terms or concepts in subparagraph (d) and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic laws and regulations of the Party taking the measure. imposition or collection of direct taxes in respect of services or service suppliers of other Parties; (e) inconsistent with Article II3.3 (Most-Favoured-Nation Treatment), provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement Chapter shall be construed to prevent the adoption or enforcement by any Member either Party of measures: (a) necessary to protect public morals or to maintain public order;5order;16 (b) necessary to protect human, animal or plant life or health;; 16 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement Chapter including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII8.5, provided that the difference in treatment is aimed at ensuring the equitable or effective6 effective17 imposition or collection of direct taxes in respect of services or service suppliers of the other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat Party; (e) inconsistent with Article 8.3, provided that the difference in treatment is posed to one the result of an agreement on the fundamental interests avoidance of societydouble taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Party is bound. 6 17 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- residents is determined with respect to taxable items sourced or located in the Member's Party’s territory; or; (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's Party’s territory; or; (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or; (iv) apply to consumers of services supplied in or from the territory of another Member the other Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's Party’s territory; or; (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's Party’s tax base. Tax terms or concepts in subparagraph (d) of this Article and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Party taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII18 (National Treatment), provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the MemberParty's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberParty's territory; or (v) distinguish or or collection of direct taxes in respect of services or service suppliers subject to tax on worldwide taxable items from of other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base.Parties; (e) inconsistent with Article II, resulting in difference in treatment provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; ; (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound. 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. . Tax terms or concepts in paragraph (ed) inconsistent with of Article IIXIV and in this footnote are determined according to tax definitions and concepts, provided that or equivalent or similar definitions and concepts, under the difference in treatment is the result domestic law of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is boundtaking the measure.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member State of measures: (a) necessary to protect public morals or to maintain public order;5order10; 10 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts;; or (iii) safety; (d) inconsistent with Article XVII6 (National Treatment), provided that the difference in treatment is aimed at ensuring the equitable or effective6 effective11 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 11 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member State under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the MemberMember State's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberMember State's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member State in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberMember State's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the MemberMember State's tax base.. collection of direct taxes in respect of services or service suppliers of other Member States; (e) inconsistent with Article II7 (Most-Favoured-Nation Treatment), provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member State is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII19, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other MembersParties; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's Party’s territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's Party’s territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's Party’s territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The 5The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures 6Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction respect of services or credit service suppliers of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base.other Members; (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The 5The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures 6Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. Tax terms or concepts in paragraph (d) of Article XIV and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Member taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health;; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII19, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other MembersParties; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the MemberParty's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberParty's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit c redit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the MemberParty's tax base. Tax terms or concepts in subparagraph (d) of Article 12 and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Party taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures: (a) necessary to protect public morals or to maintain public order;5order;5 4It is understood that the procedures under paragraph 5 shall be the same as the GATT 1994 procedures. 5The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat ; (e) inconsistent with Article II, provided that the difference in treatment is posed to one the result of an agreement on the fundamental interests avoidance of societydouble taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound. 6 Measures 6Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's ' s territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's ' s territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's ' s territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's ' s tax base. . Tax terms or concepts in paragraph (ed) inconsistent with of Article IIXIV and in this footnote are determined according to tax definitions and concepts, provided that or equivalent or similar definitions and concepts, under the difference in treatment is the result domestic law of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is boundtaking the measure.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5public (b) necessary to protect human, animal or plant life or health;; The public order exception may be invoked only where a genuine and serious threat is posed to one of the fundamental interests of society. (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts;individual (iii) safety; (d) inconsistent with Article XVII19, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which:Parties; (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberParty's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5order6; (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 6 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (d) inconsistent with Article 20, provided that the difference in treatment is aimed at ensuring the equitable or effective7 imposition or collection of direct taxes in respect of services or service suppliers of other Parties; (e) with difference in treatment provided that it is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Party is bound. 6 7 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the MemberParty's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, taxes including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberParty's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; oro (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the MemberParty's tax base. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement Chapter shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5order;9 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement Chapter including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII25, provided that the difference in treatment is aimed at ensuring the equitable or effective6 effective10 imposition or collection of direct taxes in respect of services or service suppliers of other Membersanother Party; 5 9 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 10 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the MemberParty's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's Party’s territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. (e) inconsistent with Article II23, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member a Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The 5The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures 6Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base.same (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts;; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII19, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat Parties; (e) provided that the difference in treatment is posed to one the result of an agreement on the fundamental interests avoidance of societydouble taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Party is bound. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the MemberParty's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the MemberParty's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberParty's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the MemberParty's tax base. Tax terms or concepts in subparagraph (d) of Article 12 and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Party taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement Chapter shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5order; Note: The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement Chapter including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts;; or (iii) safety; (d) inconsistent with Article XVII50.18, provided that the difference in treatment is aimed at ensuring the equitable or effective6 effective imposition or collection of direct taxes in respect of services or service suppliers of other MembersParties; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 or Note: Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member Party under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's territory; orterritory of the Party; (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; orterritory of the Party; (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or; (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; orterritory of the Party; (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's Party’s tax base. Tax terms or concepts in this subparagraph and this Note are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the law of the Party taking the measure. (e) inconsistent with Article II50.3, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries State Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement Protocol shall be construed to prevent the adoption or enforcement by any Member State Party of measures: (a) necessary to protect public morals or to maintain public order;5order6; (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement Protocol including those relating to: (i) i. the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) . the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) . safety; (d) inconsistent with Article XVIINational Treatment, provided that the difference in treatment is aimed at ensuring the equitable or effective6 effective imposition or collection of direct taxes in respect of services or service suppliers of other MembersStates Parties; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat and7 (e) inconsistent with the Most Favoured Nation obligation provided that the difference in treatment is posed to one the result of an agreement on avoidance of double taxation or provisions on the fundamental interests avoidance of societydouble taxation in any other international agreement or arrangement by which the State Party is bound. 6 Measures 7Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member State Party under its taxation system which: (i) apply a. Apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's State Party’s territory; or (ii) apply b. Apply to non-residents in order to ensure the imposition or collection of taxes in the MemberState Party's territory; or (iii) apply c. Apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply d. Apply to consumers of services supplied in or from the territory of another Member State Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the MemberState Party's territory; or (v) distinguish e. Distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determinef. Determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's State Party’s tax base. Tax terms or concepts in paragraph (d) of Article 15 and in this footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the State Party taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound.

General Exceptions. Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries Parties where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member Party of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health;; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII19, provided that the difference in treatment is in aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which:Parties; (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's Party’s territory; or (ii) apply to non-residents or residents in order to ensure the imposition or collection of taxes in the Member's Party’s territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; oror 6 Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Party under its taxation system which: (iv) apply to consumers of services supplied in or from the territory of another Member Party in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's Party’s territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, losslose, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's Party’s tax base. Tax terms or concepts in subparagraph (d) of Article 12 and in the footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Party taking the measure. (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member Party is bound.

General Exceptions. ‌ Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures: (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The ; (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound. 5The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures 6Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. . Tax terms or concepts in paragraph (ed) inconsistent with of Article IIXIV and in this footnote are determined according to tax definitions and concepts, provided that or equivalent or similar definitions and concepts, under the difference in treatment is the result domestic law of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is boundtaking the measure.

General Exceptions. ‌ Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services, nothing in this Agreement shall be construed to prevent the adoption or enforcement by any Member of measures:: 4It is understood that the procedures under paragraph 5 shall be the same as the GATT 1994 procedures. (a) necessary to protect public morals or to maintain public order;5 (b) necessary to protect human, animal or plant life or health; (c) necessary to secure compliance with laws or regulations which are not inconsistent with the provisions of this Agreement including those relating to: (i) the prevention of deceptive and fraudulent practices or to deal with the effects of a default on services contracts; (ii) the protection of the privacy of individuals in relation to the processing and dissemination of personal data and the protection of confidentiality of individual records and accounts; (iii) safety; (d) inconsistent with Article XVII, provided that the difference in treatment is aimed at ensuring the equitable or effective6 imposition or collection of direct taxes in respect of services or service suppliers of other Members; 5 The ; (e) inconsistent with Article II, provided that the difference in treatment is the result of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is bound. 5The public order exception may be invoked only where a genuine and sufficiently serious threat is posed to one of the fundamental interests of society. 6 Measures 6Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which: (i) apply to non-resident service suppliers in recognition of the fact that the tax obligation of non- non-residents is determined with respect to taxable items sourced or located in the Member's territory; or (ii) apply to non-residents in order to ensure the imposition or collection of taxes in the Member's territory; or (iii) apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or (iv) apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member's territory; or (v) distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or (vi) determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member's tax base. . Tax terms or concepts in paragraph (ed) inconsistent with of Article IIXIV and in this footnote are determined according to tax definitions and concepts, provided that or equivalent or similar definitions and concepts, under the difference in treatment is the result domestic law of an agreement on the avoidance of double taxation or provisions on the avoidance of double taxation in any other international agreement or arrangement by which the Member is boundtaking the measure.