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29 DE OUTUBRO DE 1993

34-(19)

In witness whereof, the undersigned, duly authorised thereto, have signed this Convention.

Done in duplicate at Dublin, this 1st day of June 1993 in the Portuguese and English languages, both texts being equally authoritative.

For the Government of the Portuguese Republic: For the Government of Ireland:

PROTOCOL

At the moment of signing the Convention between the Portuguese Republic and Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following provisions which shall be an integral part of the Convention.

1 — The term «income» as used in this Convention includes, in particular, capital gains.

2 — Notwithstanding the provisions of article 5, an enterprise of a Contracting State that carries on business of a permanent nature in the other Contracting State

through its own employees or any other personnel engaged for such purpose for a period or periods amounting to or exceeding in the agregate 120 days in any twelve month period shall be deemed to have a permanent establishment in that other State.

3 — Notwithstanding the provisions of article 28, article 8, paragraph 4 of article 13 and paragraph 3 of article 15 shall have effect in both Contracting States with respect to the assessment periods begining on or after 1 January, 1988.

In witness whereof, the undersigned, duly authorised thereto, have signed this Protocol.

Done in duplicate at Dublin, this 1st day of June 1993, in the Portuguese and English languages, both texts being equally authoritative.

For the Government of the Portuguese Republic:

For the Government of Ireland:

A Divisão de Redacção e Apoio Audiovisual.