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II SÉRIE-A — NÚMERO 78 108_______________________________________________________________________________________________________________

3. The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages, pensions, and other similar

remuneration in respect of services rendered in connection with a business carried on by a Contracting State

or a political or administrative subdivision or a local authority thereof.

ARTICLE 20

Students and Apprentices

1. Payments which a student or business apprentice who is or was immediately before visiting a

Contracting State a resident of the other Contracting State and who is present in the first-mentioned State

solely for the purpose of his education or training receives for the purpose of his maintenance, education or

training shall not be taxed in that Stateprovided that such payments arise from sources outside that State.

2. Notwithstanding the provisions of paragraph 1, a student or business apprentice visiting a Contracting

State for the purpose of his education or training shall be exempted from tax in that State on the remuneration

from employment in that State of an amount not exceeding 9,000 USD per annum during a period not

exceeding five years, from the day of his first arrival in that Contracting State, provided that such employment

is directly related to his education or training.

ARTICLE 21

Other Income

1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing

Articles of this Agreement shall be taxable only in that State.

2. The provisions of paragraph 1 shall not apply to the income, other than income from immovable

property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a

Contracting State, carries on business in the other Contracting State through a permanent establishment

situated therein, or performs in that other State independent personal services from a fixed base situated

therein, and the right or property in respect of which the income is paid is effectively connected with such

permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may

be, shall apply.

ARTICLE 22

Methods for Elimination of Double Taxation

1. In Viet Nam, double taxation shall be eliminated as follows:

(a) Where a resident of Viet Nam derives income which under the law of Portugal and in accordance with

this Agreement may be taxed in Portugal, Viet Nam shall allow as a credit against its tax on the income an

amount equal to the tax paid in Portugal. The amount of credit, however, shall not exceed the amount of the

Vietnamese tax on that income, profits or gains computed in accordance with the taxation laws and

regulations of Viet Nam.

(b) Where a resident of Viet Nam derives income which in accordance with any provision of the

Agreement are taxable only in Portugal, Viet Nam may nevertheless, in calculating the amount of tax on the

remaining income of such resident in Viet Nam, take into account the exempted income.

2. In Portugal, double taxation shall be eliminated as follows:

(a) Where a resident of Portugal derives income which, in accordance with the provisions of this

Agreement, may be taxed in Viet Nam, Portugal shall allow as a deduction from the tax on the income of that

resident an amount equal to the income tax paid in Viet Nam. Such deduction shall not, however, exceed that

part of the tax on income, as computed before the deduction is given, which is attributable to the income

which may be taxed in Viet Nam.