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of <h1>Article 28: Conditions for Reservations in Tax Treaty Measures to Prevent Base Erosion and Profit Shifting Explained</h1> Article 28 of the Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting outlines the conditions under which reservations to the Convention can be made. Generally, reservations are not allowed unless explicitly permitted by specific provisions within the Convention, such as those related to transparent entities, dual resident entities, and methods for eliminating double taxation, among others. Parties choosing to apply arbitration under Part VI may make reservations about eligible cases, subject to acceptance by other parties. Reservations must be confirmed upon ratification and can be withdrawn or replaced with more limited ones, with specific procedures for their effectuation.
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