ANNEX3 CO-OPERATION IN TAXATION AND RELATED MATTERS PREAMBLE The High Contracting Parties: RECALLING the provisions of Chapter Four of the Protocol which require co-operation on taxation and related matters; RECOGNISING the need to take such steps as are necessary to maximise the co-operation of State Parties in taxation matters and to co-ordinate the tax regimes of the State Parties; and DETERMINED to take such steps as are necessary to maximise the cooperation of the State Parties in taxation matters; HEREBY AGREE as follows: 1. 2. ARTICLE 1 DEFINITIONS In this Annex, terms and expressions defined in Article 1 of the Protocol shall bear the same meaning unless the context otherwise requires. In this Annex, unless the context otherwise requires: "customs duty" means a tax normally applied to imported goods; "direct tax" means a tax levied under its domestic laws, by a country on persons (including juristic persons), in respect of income, capital gains, net worth, property, donations and gifts and includes estate duties; "double taxation" means an imposition of similar taxes by two or more tax jurisdictions on the same taxpayer in respect of the same income or capital; "a-commerce, e-billing, or e-Customs Clearance" means the conduct of financial transactions, or customs clearance, by electronic means, "exceptional cases" means, in relation to tax incentives, those exceptions to the guidelines envisaged in Article 4 agreed to by State Parties, on the use of tax incentives within the Region 42

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