Africa Export-Import Bank (Membership of Zimbabwe and Branch Office Agreement) Act, 2005 exempt from any obligation relating to the payment, withholding or collection of any tax or duty out of funds owned by, or otherwise appertaining to, the Bank. 2. Without prejudice to the generality of the provisions of paragraph 1 of this Article, each Participating State shall take all necessary action to ensure that the property and assets of the Bank, its capital, reserves and dividends, loans, credits, guarantees, securities, and other investments and transactions, interest, commissions, fees, profits, gains, proceeds or realisation and other income, return and moneys of any kind, accruing, appertaining or payable to the Bank from any source shall be exempt from all forms of taxes, duties, charges, levies, and imposts of any kind whatsoever, including stamp duty and other documentary taxes, heretofore levied or hereafter imposed in its territory. 3. The provisions of paragraphs 1 and 2 of this Article shall be applied without prejudice to the right of the Participating States to tax their residents in the manner each state deems appropriate. Article XV Fiscal Exemptions, Financial Facilities, Privileges and Concessions 1. The Bank shall be accorded by each Participating State a status not less favourable than that of a non-resident corporation, and shall enjoy all fiscal exemptions, financial facilities, privileges and concessions granted to international organisations, banking establishments and financial institutions by the Participating States. 2. Without prejudice to the generality of the provisions of Article XI and paragraph 1 of this Article by reason of the following enumeration, the Bank may freely and without any restriction, but to the extent necessary to implement its purpose and carry out its functions, set forth in the Charter: (i) carry on all forms of banking business and financial services authorised under the Charter; (ii) purchase, hold and dispose of national currencies; (iii) purchase, hold and dispose of convertible currencies, securities, bills of exchange and negotiable instruments, and transfer the same to, from or within the territory of any Participating State; (iv) open, maintain and operate accounts in national currencies in the territories of the Participating States; (v) open, maintain and operate convertible currency accounts in the territories and outside the territories of the Participating States; (vi) raise funds and make loans in convertible currencies, provided that it shall seek the consent of the Participating State in whose market it intends to raise funds; and (vii) carry out any operation authorised under the Charter. -5-

Select target paragraph3