第5條
This Article shall not apply to any provision of the laws of a Contracting Party which: (a) is designed to prevent the avoidance or evasion of taxes; (b) does not permit the deferral of tax arising on the transfer of an asset where the subsequent transfer of the asset by the transferee would be beyond the taxing jurisdiction of the Contracting Party under its laws; (c) provides for consolidation of group entities for treatment as a single entity for tax purposes; (d) provides for the transfer of losses within a group of companies; (e) does not allow tax rebates, credits or an exemption in relation to dividends paid by a company that is a resident of that Party for purposes of its tax; or (f) is otherwise agreed by the competent authorities of the Contracting Parties to be unaffected by this Article.