AGREEMENT BETWEEN

SOVEREIGN INVESTMENTS 1.  Notwithstanding any provision of this Agreement, investments of a Contracting State in the other Contracting State and income derived from such investments mentioned in Articles 10 and 11 of this Agreement shall be taxable only in the first-mentioned Contracting State. 2.  For the purposes of this Article and in respect of the Kingdom of Saudi Arabia, “investments of a Contracting State” referred to in paragraph 1 of this Article means investments made by: a)  that Contracting State, any administrative or political subdivision, local authority, statutory body, agency or instrumentality or a public law entity thereof including: (i)  the Saudi Central Bank (SAMA); (ii)  the Saudi Fund for Development; (iii)  the Public Investment Fund; (iv)  the General Organization for Social Insurance, b)  the Saudi Arabian Oil Company (Saudi Aramco) as long as 80 per cent or more of it is owned directly or indirectly by persons referred to in subparagraph a) of this paragraph; c)  any entity that is directly or indirectly wholly owned by persons mentioned in subparagraphs a) or b) of this paragraph; or d)  any other similar entity as may be specified and agreed between the competent authorities of the Contracting States through an exchange of notes. 3.  For the purposes of this Article and in respect of the Republic of Croatia, “investments of a Contracting State” referred to in paragraph 1 of this Article mean investments made by: a)  that Contracting State, any administrative or political subdivision, local authority, statutory body, agency or instrumentality or a public law entity thereof including: (i)  the Croatian Nation Bank; (ii)  the Croatian Bank for Reconstruction and Development; b)  any entity that is directly or indirectly wholly owned by persons mentioned in subparagraph a) of this paragraph; or c)  any other similar entity as may be specified and agreed between the competent authorities of the Contracting States through an exchange of notes.