第4條
Notwithstanding the provisions of paragraphs 2 and 3 of this Article, dividends arising in a Contracting Party are exempt from tax in that Party, if they are paid: (a) in the case of the Hong Kong Special Administrative Region: (i) to the Government of the Hong Kong Special Administrative Region; (ii) to the Hong Kong Monetary Authority; (iii) to any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as may be agreed from time to time between the competent authorities of the Contracting Parties; (b) in the case of New Zealand: (i) to the Government of New Zealand; (ii) to the Reserve Bank of New Zealand; (iii) to the New Zealand Export Credit Office; (iv) to the New Zealand Superannuation Fund; (v) to any institution wholly or mainly owned by the Government of New Zealand as may be agreed from time to time between the competent authorities of the Contracting Parties.