Article 9(1) of the Protocol of March

17, 1995 (the ‘‘Protocol’’), amended paragraph 3 of Article XVIII (Pensions and Annuities) of the Convention to expand the definition of ‘‘pensions’’ to include a retirement ‘‘arrangement.’’ Article 9(3) of the Protocol added paragraph 7 to Article XVIII of the Convention, allowing a citizen or resident of one state to defer taxation in that state on income accrued as the beneficiary of a trust, company, organization or other arrangement that is a resident of, and generally exempt from income taxation in the other state, until the income is distributed from the plan, or any plan substituted therefor, provided that the arrangement is operated exclusively to provide pension, retirement or employee benefits. Under Article 21(2)(a) of the Protocol, these revisions of Article XVIII apply to amounts paid or credited on or after January 1, 1996.

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