Yes, I mentioned two. There's been discussion about mandatory binding arbitration. That's a concern because these panels meet in secret. There's not much transparency. It puts a lot of the source countries at a disadvantage on that.
In terms of the elements of article 17, it would require other countries to also adopt similar provisions on this, in terms of the relief from what they've called “economic double taxation” from transfer pricing. Some countries will want to opt out of that as well.