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TERMINATION 1. This Convention shall remain in force indefinitely. Either Contracting State may terminate the Convention, through diplomatic channel, by giving written notice of termination at least six months before the end of any calendar year beginning after the expiry of five years from the date of entry into force of this Convention. 2. In such event this Convention shall cease to apply: a) with regard to taxes withheld at source, in respect of amounts paid after the end of the calendar year in which such notice is given; and b) with regard to other taxes, in respect of taxable years beginning after the end of the calendar year in which such notice is given. In witness whereof the undersigned, being duly authorized thereto, have signed this Convention. Done in duplicate at Kiev, this 4th day of Shawwal 1432 corresponding to the 2nd day of September 2011, in the Arabic, Ukrainian and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. PROTOCOL At the moment of signing the Convention between the Government of the Kingdom of Saudi Arabia and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Tax Evasion with respect to Taxes on Income and on Capital, the undersigned have agreed that the following provisions shall form an integral part of the Convention. It is understood that the term “place of effective management” under the Convention means the place where an enterprise is actually managed and controlled or the place where the decision-making at the highest level on the important policies essential for the management of a company takes place. With reference to Paragraph 1 of Article 4 of the Convention, the term "resident of a Contracting State" also includes a legal person organized under the laws of a Contracting State and that is not liable to tax or generally exempt from tax in that State and is established and maintained in that State either: a) for a charitable, educational, scientific, or other similar purpose; or b) to provide pensions or other similar benefits to employees. 3. With reference to Article 7 of the Convention: a) Notwithstanding other provisions, the business profits derived by an enterprise of a Contracting State from the exportation of merchandise to the other Contracting State shall not be taxed in that other Contracting State. Where export contracts include other activities carried on through permanent establishment situated in the other Contracting State, profits derived from such activities shall be taxed in the other Contracting State. b) The term “business profits” includes any profits from any business activity, such as profit from manufacturing, mercantile, banking, insurance, from the operation of inland transportation, the furnishing of services and the rental of tangible personal movable property. Such a term does not include the performance of personal services by an individual either as an employee or in an independent capacity. c) Each Contracting State shall apply its domestic law with regard to insurance activities. In witness whereof the undersigned, being duly authorized thereto, have signed this Protocol. Done in duplicate at Kiev, this 4th day of Shawwal 1432 corresponding to the 2nd day of September 2011, in the Arabic, Ukrainian and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail.