Debates Parlamentares - Diário 078S1, p. 107 (2016-05-05)

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5 DE MAIO DE 2016 107_______________________________________________________________________________________________________________

3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an

employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a

Contracting State may be taxed in that Contracting State.

ARTICLE 16

Directors' Fees

Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a

member of the board of directors or supervisory board or of another similar organ of a company which is a

resident of the other Contracting State may be taxed in that other Contracting State.

ARTICLE 17

Entertainers and Sportspersons

1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting

State as an entertainer, such as a theater, motion picture, radio or television artiste, or a musician, or as a

sportsperson, from his or her personal activities as such exercised in the other Contracting State, may be

taxed in that other Contracting State.

2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in his or

her capacity as such accrues not to the entertainer or sportsperson himself or herself but to another person,

that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in

which the activities of the entertainer or sportsperson are exercised.

3. Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainers or

sportspersons who are residents of a Contracting State from activities in the other Contracting State under an

arrangement of cultural exchange between the Governments of both Contracting States shall be exempt from

tax in that other Contracting State.

ARTICLE 18

Pensions

Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a

resident of a Contracting State in consideration of past employment shall be taxable only in that State.

ARTICLE 19

Government Service

1. Salaries, wages and other similar remuneration paid by a Contracting State or a political or

administrative subdivision or a local authority thereof to an individual in respect of services rendered to that

State or subdivision or authority shall be taxable only in that State. However, such salaries, wages and other

similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that

State and the individual is a resident of that State who:

(a) is a national of that State; or

(b) did not become a resident of that State solely for the purpose of rendering the services.

2. Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration paid by, or

out of funds created by, a Contracting State or a political or administrative subdivision or a local authority

thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable

only in that State. However, such pensions and other similar remuneration shall be taxable only in the other

Contracting State if the individual is a resident of, and a national of, that State.

5 DE MAIO DE 2016 107_______________________________________________________________________________________________________________3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State. ARTICLE 16 Directors' FeesDirectors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or supervisory board or of another similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State. ARTICLE 17 Entertainers and Sportspersons1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theater, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his or her personal activities as such exercised in the other Contracting State, may be taxed in that other Contracting State. 2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in his or her capacity as such accrues not to the entertainer or sportsperson himself or herself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised. 3. Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainers or sportspersons who are residents of a Contracting State from activities in the other Contracting State under an arrangement of cultural exchange between the Governments of both Contracting States shall be exempt from tax in that other Contracting State.ARTICLE 18 PensionsSubject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State. ARTICLE 19 Government Service 1. Salaries, wages and other similar remuneration paid by a Contracting State or a political or administrative subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (a) is a national of that State; or (b) did not become a resident of that State solely for the purpose of rendering the services. 2. Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration paid by, or out of funds created by, a Contracting State or a political or administrative subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. However, such pensions and other similar remuneration shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.

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