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II SÉRIE — NÚMERO 60

authority thereof to any individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State; b) However, such 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 national of that State; or //') did not become a resident of that State solely for the purpose of rendering the services.

2:

a) Any pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State;

b) However, such pensions shall be taxable only in the other Contracting State if the individual is a resident of and a national of that State.

3 — The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pension in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.

ARTICLE 20 Students

1 — Payments which a student or business, technical, agricultural or forestry apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the fust-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 State, provided that such payments arise from sources outside that State.

2 — A student at university or other institution for higher education in a Contracting State, or a business, technical, agricultural or a forestry apprentice who is present in the other Contracting State for a period or periods not exceeding 183 days in the calendar year concerned and who is or was immediately before such visit a resident of the first--mentioned State, shall not be taxed in the other Contracting State in respect of remuneration for services rendered in that other State, provided that the services are in connection with his studies or training and the remuneration constitutes earnings necessary for his maintenance.

ARTICLE 21 Other Income

1 — Items of income of a resident of a Contracting State, arising in the other Contracting State, not dealt with in the foregoing Articles of this Convention, may be taxed in that other State.

2 — The provisions of Article 7 or Article 14, as the case may be, shall apply to the income, wherever arising, not dealt with in the foregoing Articles of this Convention, other than income from immovable property as defined in paragraph 2 of Article 6, derived by a resident of a Contracting State who 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, provided that the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base.

ARTICLE 22

Methods for elimination of double taxation

1 — In Czechoslovakia, double taxation will be avoided in the following manner:

a) Where a resident of Czechoslovakia derives income which, in accordance with the provisions of this Convention, may be taxed in Portugal, Czechoslovakia shall, subject to the provisions of subparagraph b), c) and d) of this Article, exempt such income from tax but may, in calculating tax on the remaining income of that person, apply the rate of tax which would have been applicable if the exempted income had not been so exempted;

b) Czechoslovakia when imposing taxes on its residents includes in the basis upon which such taxes are imposed the items of income which according to the provisions of Articles 10, 11 and 12 of this Convention may also be taxed in Portugal. Czechoslovakia shall allow as a deduction from the amount of tax computed on such a basis an amount equal to the tax paid in Portugal. Such deduction shall not, however, exceed that part of the Czechoslovakia tax, as computed before the deduction is given, which is appropriate to the income which, in accordance with the provisions of Article 10, 11 and 12 of this Convention maybe taxed in Portugal;

c) The provisions of head b) of this paragraph shall also apply when the Portuguese income tax appropriate to dividends, interest and royalties has been wholly relieved or reduced as if no such relief had been given or no such reduction had been allowed;

d) Notwithstanding the provisions of head c) of this paragraph, dividends attributed or paid by a company which is a resident of Portugal to a company which is a resident of Czechoslovakia, shall be exempted from Czechoslovak tax to the extent to which, in accordance with the laws of Czechoslovakia, the dividends have been exempted from Czechoslovak tax if the first-mentioned company had been a resident of Czechoslovakia and not a resident of Portugal.

2:

a) Where a resident of Portugal derives income which, in accordance with the provisions of this Convention, may be taxed in Czechoslovakia, Portugal shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Czechoslovakia.

Such deduction shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable to the income which may be taxed in Czechoslovakia;

b) Where in accordance with any provision of the Convention income derived by a resident of Portugal is exempt from tax in this State, Portugal may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

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