[...]
2 Paragraph 6 of Article 10 of the Convention shall be deleted and replaced by the following:
“6 Notwithstanding any provision in this Convention, a Contracting State may impose on the earnings of a company attributable to permanent establishments in that State, or on the alienation of immovable property situated in that State by a company carrying on a trade in immovable property, tax in addition to the tax which would be chargeable on the earnings of a company that is a resident of that State, provided that the rate of such additional tax so imposed shall not exceed the percentage limitation provided for under subparagraph (a) of paragraph 2 of the amount of such earnings which have not been subjected to such additional tax in previous taxation years. For the purpose of this provision, the term earnings means:
2 New subparagraphs (e) and (f) shall be added to paragraph 7 of Article 11 of the Convention as follows:
Article 26 of the Convention shall be deleted and replaced by the following:
2 In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation
