Debates Parlamentares - Diário 078S1, p. 112 (2016-05-05)

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II SÉRIE-A — NÚMERO 78 112_______________________________________________________________________________________________________________

PROTOCOL TO THE AGREEMENT BETWEEN THE PORTUGUESE REPUBLIC AND THE SOCIALIST

REPUBLIC OF VIET NAM FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF

FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

On signing the Agreement between the Portuguese Republic and the Socialist Republic of Viet Nam for the

Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

(hereinafter referred to as “the Agreement”), the signatories have agreed that the following provisions shall

form an integral part of the Agreement:

1. Entitlement to the Benefits of the Agreement:

(a) It is understood that the provisions of the Agreement shall not be interpreted so as to prevent the

application by a Contracting State of the anti-avoidance provisions provided for in its domestic law;

(b) It is understood that the benefits foreseen in the Agreement shall not be granted to a resident of a

Contracting State which is not the beneficial owner of the income derived from the other Contracting State;

the main purposes of any person concerned with the creation or assignment of the property or right in respect

of which the income is paid to take advantage of those provisions by means of such creation or assignment.

2. With respect to Articles 10, 11 and 12, if after the entry into force of this Agreement, Viet Nam has

signed an Agreement or Convention for the avoidance of double taxation with a State which is a member of

the European Union, and that Agreement or Convention contains lower withholding tax rates (including zero

rates) than those provided for under this Agreement, these rates will automatically replace the rates of this

Agreement, from the date of entry into force of the Agreement or Convention between Viet Nam and that

State.

3. The competent authorities of both Contracting States shall notify each other the procedures for applying

the Agreement as provided for by their internal laws.

IN WITNESS WHEREOF the undersigned, being duly authorized thereto, have signed this Protocol.

II SÉRIE-A — NÚMERO 78 112_______________________________________________________________________________________________________________PROTOCOL TO THE AGREEMENT BETWEEN THE PORTUGUESE REPUBLIC AND THE SOCIALIST REPUBLIC OF VIET NAM FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME On signing the Agreement between the Portuguese Republic and the Socialist Republic of Viet Nam for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (hereinafter referred to as “the Agreement”), the signatories have agreed that the following provisions shall form an integral part of the Agreement: 1. Entitlement to the Benefits of the Agreement: (a) It is understood that the provisions of the Agreement shall not be interpreted so as to prevent the application by a Contracting State of the anti-avoidance provisions provided for in its domestic law; (b) It is understood that the benefits foreseen in the Agreement shall not be granted to a resident of a Contracting State which is not the beneficial owner of the income derived from the other Contracting State; (c) It is understood that the provisions of the Agreement shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the property or right in respect of which the income is paid to take advantage of those provisions by means of such creation or assignment. 2. With respect to Articles 10, 11 and 12, if after the entry into force of this Agreement, Viet Nam has signed an Agreement or Convention for the avoidance of double taxation with a State which is a member of the European Union, and that Agreement or Convention contains lower withholding tax rates (including zero rates) than those provided for under this Agreement, these rates will automatically replace the rates of this Agreement, from the date of entry into force of the Agreement or Convention between Viet Nam and that State. 3. The competent authorities of both Contracting States shall notify each other the procedures for applying the Agreement as provided for by their internal laws. IN WITNESS WHEREOF the undersigned, being duly authorized thereto, have signed this Protocol.

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