Article 12

At the end of paragraph 11 add—

“(7)

Where the underlying subject matter of a relevant contract consists of or includes income from any of the following—

(a)

land (wherever situated),

(b)

shares in a company,

(c)

rights of a unit holder under a unit trust scheme,

the underlying subject matter shall not be treated, by reason only of that income, as being land or such shares or rights (as the case may be).”.