Article XI of the Protocol amends Article 22 (Governmental Functions) of the

Convention. The Protocol adds two new paragraphs to the Article that expand the scope of "public funds of a Contracting State" and "employment by a Contracting State" to cover more than the Contracting States themselves. Paragraphs (2) and (3) expand these terms to mean public funds of, and employment by,

(i) a Contracting State or a political subdivision or local authority thereof; (ii) a corporation that is wholly owned by a Contracting State or a political subdivision or local authority thereof, provided the corporation performs functions of a governmental nature; and

(iii) a body that is treated for tax purposes the same as a Contracting State or a political subdivision or local authority thereof and that performs functions of a Governmental nature.