7 DE MAIO DE 1980

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ARTICLE 24 (Mutual agreement procedure)

1 — Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of article 24, to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.

2 — The competent authority sail endeavour, if the objection appears to it to be justified and it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Convention.

3 — The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention.

4 — The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

ARTICLE 25 (Exchange of information)

1 — The competent authorities of the Contracting Sta'.es shall exchange such information as is necessary for the carrying out of this Convention and of the domestic laws of the Contracting States concerning taxes covered by this Convention insofar as the taxation thereunder is in accordance with this Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons or authorities, including courts, other than those concerned with the assessment, collection, enforcement or prosecution of taxes which are the subject of the Convention.

2 — In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation:

a) To carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;

6) To supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;

c) To supply information which would disclose any trade, business, industrial, commercial or professional secret or process, or information, the disclosure of which would be contrary to public policy (ordre public).

ARTICLE 26 (Diplomatic agents and consular officers)

Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements.

ARTICLE 27 (Entry into force)

1 — This Convention shall be ratified and the instruments of ratification shall be exchanged at Praga as soon as possible.

2 — The Convention shall enter into force on the thirtieth day after the exchanged of instruments of ratification and its provisions shall have effect for the first time:

a) In respect of taxes withheld at source, the

fact giving rise to them appearing on or after the 1st January in the calendar year next following that in which the Convention enters into force;

b) In respect of other taxes on income, as to

income arising in the calendar year next following that in which the Convention enters into force.

ARTICLE 28 (Tramlnatlon)

This Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year. In such event, the Convention shall cease to have effect:

a) In respect of taxes withheld at sources the

fact giving rise to them appearing on or after the 1st January in the calendar year next following that in which the notice is given;

b) In respect of other taxes on income, as to

income arising on or after the 1st January in the calendar year next following that in which the notice is given.

Done at Lisbon this 28th day of June 1978 in duplicate in the English language.

For the Portuguese Republic:

For the Czechoslovak Socialist Republic:

PROPOSTA DE LEI N.° 324/1 SOBRE ASSOCIAÇÕES DE MUNICIPIOS

Na conjuntura político-administrativa decorrente da aplicação da Lei das Finanças Locais, torna-se imperioso dotar os municipios de instrumentos jurídicos indispensáveis à gestão racional dos seus actuais re-