(b) iv) restricting tax incentives to particular tax payers, usually non-residents; v) promotion of tax incentives as vehicles for tax minimisation; or vi) the absence of substantial activity in the jurisdiction to qualify for a tax incentive; introducing tax legislation that prejudices another Member State's economic policies, activities, or the regional mobility of goods, services, capital or labour. 4. Member States will develop guidelines for tax incentives in SADC, including provision for exceptional cases. 5. In order to advance a competition policy in SADC, Member States will develop a fiscal framework for tax incentives that will, amongst other things, focus on: (a) the effectiveness of proposed tax incentives in achieving their stated policy goals; (b) the revenue costs likely to be suffered by the fiscus of Member States as a result of the application of proposed tax incentives; (c) the extent to which the absence of tax sparing arrangements in treaties of Member States for the avoidance of double taxation reduce the effectiveness of tax incentives, specifically those aimed at attracting foreign direct investments; (d) the impact that proposed tax incentives will have on the costs of, or burden on tax administration in the Community; and (e) the effects that tax incentives have on the overall distribution of the tax burden within a Member State. ARTICLE 5 TAX TREATIES 1. Member States will develop a common policy for the negotiation of tax treaties between or amongst themselves or with countries outside the Community. 2. Member States will in accordance with their constitutional procedures strive to ensure the speedy negotiation, conclusion, ratification and effective implementation of tax treaties. 3. Member States will take such steps as are necessary to establish amongst themselves a comprehensive treaty network, which will assist in expediting the 7