To the Convention between the United States of America and New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. 　　At the signing of the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, concluded today between the United States of America and New Zealand, the undersigned have agreed that the following provisions shall form an integral part of that Convention. 　　1. With reference to Articles 10, 11 and 12 　　If in any future double taxation convention with any other country, being a member of the Organization for Economic Cooperation and Development, New Zealand should limit its taxation at source on any dividends, interest or royalties to a rate lower than the one provided for in any of such articles, New Zealand shall without undue delay enter into negotiations with the United States to review the appropriate article with a view to providing the same treatment on a reciprocal basis. 　　2. With reference to Articles 7, 12 and 21 　　So long as New Zealand continues to tax the income of film renters according to section 224 of the Income Tax Act of 1976 (including any subsequent enactment which does not affect the general principle thereof) and to exempt from tax in accordance with that section certain payments received from such film renters by persons not resident in New Zealand for the purposes of New Zealand tax, the provisions of Articles 7, 12 and 21 of the Convention shall not affect the taxation by New Zealand of such income or the exemption by New Zealand of such payments 　　DONE at Wellington in duplicate, this 23rd day of July 1982. FOR THE UNITED STATES OF AMERICA: 　　　　　　　　 FOR NEW ZEALAND: (s) Charles B. Salmon, Jr. 　　　　　　　　　　　　 (s)Warren E. Cooper