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Article 19 of the Convention shall be deleted and replaced by the following:

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Article 26 of the Convention shall be deleted and replaced by the following:

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• 4 There shall be added to Article 29 of the Convention a new paragraph 7, written as follows:

  • “7

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    • (c) Notwithstanding the provisions of Article 11, interest arising in a Contracting State and paid to an organisation that was constituted and is established in the other Contracting State and is operated exclusively to administer or provide benefits under one or more pension or retirement plans, shall be exempt from tax in the first-mentioned State provided that:

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      • (ii) the interest is not derived from the carrying on a trade or a business by the organisation or from an associated person within the meaning of subparagraphs (a) or (b) of Article 9.”

• 5 There shall be added to Article 29 of the Convention a new paragraph 8, written as follows:

  • “8 Where an enterprise of a Contracting State that is exempt from tax in that State on the profits of its permanent establishments which are not situated in that State derives income from the other Contracting State, and that income is attributable to a permanent establishment which that enterprise has in a third jurisdiction, the tax benefits that would otherwise apply under the other provisions of the Convention will not apply to any item of income on which the combined tax in the first-mentioned State and in the third jurisdiction is less than 60 per cent of the tax that would be imposed in the first-mentioned State if the income were earned or received in that State by the enterprise and were not attributable to the permanent establishment in the third jurisdiction. Any dividends, interest, or royalties to which the provisions of this paragraph apply shall be subject to tax in the other State at a rate not exceeding 15 per cent of the gross amount thereof. Any other income to which the provisions of this paragraph apply shall be subject to tax under the provisions of the domestic law of the other State, notwithstanding any other provision of the Convention. The preceding provisions of this paragraph shall not apply:

    • (a) if the income derived from the other State is in connection with or incidental to the active conduct of a trade or business carried on by the permanent establishment in the third jurisdiction (other than the business of making or managing investments unless these activities are banking or insurance activities carried on by a bank or insurance company);

• 6 There shall be added to Article 29 of the Convention a new paragraph 9, written as follows:

  • “9 Subject to reciprocity, the exemptions from tax and other tax benefits provided for by French laws for the benefit of the French State, its local authorities or their agencies or instrumentalities whose activities are not the carrying on of a trade or business, shall apply in the same conditions respectively to:

    • (a) the Canadian State, its provinces, or organisations whose activities are not the carrying on of a trade or business, created within the framework of an agreement concluded or approved by the Contracting States;

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