Article II

DEFINITIONS

AN AGREEMENT BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA

AND THE GOVERNMENT OF THE KINGDOM OF SAUDI ARABIA

1. In this Agreement, unless the context otherwise requires: a) The terms “a Contracting Party”

resident of a Contracting Party, or a corporation organized in a Contracting Party, engaged in the international operation of a ship or ships or aircraft from its participation in a pool, an alliance, joint businesses, international operating agency, or other venture that is itself engaged in the international, operation of a ship or ships or aircraft; f) For Saudi tax purposes, open tax able years are taxable years for which taxes have not been paid for any reason. For U.S. tax purposes, open taxable years are taxable years for which the statute of limitations is not closed. g) The term “competent authority”

FOR RECIPROCAL EXEMPTION OF TAXES ON INCOME FROM THE INTERNATIONAL OPERATION OF A

SHIP OR SHIPS OR AIRCRAFT

The Government of the United States of America and the Government of the Kingdom of Saudi Arabia, hereinafter “the Contracting Parties”, desiring to conclude an Agreement for reciprocal exemption with respect to taxes levied on income from the international operation of a ship or ships or aircraft,

Have agreed as follows: