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b) In case of Bulgaria:

0 The tax on total income; it) The profit tax;

(hereinafter referred to as «Bulgarian tax»).

4 — The Convention shall apply also to any identical or substancially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.

chapter h Definitions

. Article 3 General definitions

1 — For the purposes of this Convention, unless the context otherwise requires:

a) The term «Portugal» means the territory of the Portuguese Republic situated in the European Continent, the archipelagoes of Azores and Madeira, the respective territorial sea and any other zone in which, in acorddance wich the laws of Portugal and international law, the Portuguese Republic has its jurisdiction or sovereign rights with respect to the exploration and exploitation of the natural resources of the sea bed and subsoil, and of the superjacent waters;

b) The term «Bulgaria» means the Republic of Bulgaria and when used in a geographical sense means the territory and the territorial sea over which it exercises its State sovereignty, as well as the continental shelf and the exclusive economic zone over which it exercises sovereign rigths or jurisdiction in conformity with international law;

c) The terms «a Contracting State» and «the other Contracting State» mean Portugal or Bulgaria, as the contex requires;

d) The term «person» includes an individual, a legal person, a company and any other body of persons;

e) The term «company» means any body corporate or any entity which is treated as a body corporate for tax purposes;

f) The terms «enterprise of a Contracting State» and «enterprise of the other Contracting State» mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;

g) The term «international traffic* means any transport by a ship, aircraft or road transport Vehicle operated by an enterprise which has its place of effective management in a Contracting State, except when the ship, aircraft or road transport vehicle is operated solely between places in the other Contracting State;

h) The term «competent authority* means:

i) In the case of Portugal, the Minister of Finance, the Director General of Taxation

(director-geral das Contribuições e Impostos) or their authorized representative; i'O In the case of Bulgaria, the Minister of Finance or his authorized representative;

i) The term «national» means:

0 Any individual possessing the nationality of

a Contracting State; it) Any legal person, association or other entity deriving its status as such from the laws in force in a Contracting State.

2 — As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall unless the context otherwise requires, have the meanning which it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.

Article 4 Resident

1 —For the purposes of this Convention, a person is a resident of a Contracting State:

a) In the case of Bulgaria, if the person is liable to taxation according to Bulgarian domestic law by reason of his nationality, head-office or registration;

b) In the case of Portugal, if the person is liable to tax therein by reason of his domicile, residence, place* of management or any other criterion of a similar nature.

But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

2 — Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows:

a) He shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests);

b) If the State in which he has his centre of vitai interests cannot be.determined, he shall be deemed to be a resident of the State in which he has an habitual abode;

c) If he has an habitual abode in both States or in neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

3 — Where by reason of the provisions of paragraph 1 a person other than an individual is a resident oí bo\J-\ Contracting States, then it shall be deemed to be a resident of the State in which its place of efective management is situated.

Article 5

Permanent establishment

1 — For the purposes of this Convention, the term «permanent establishment» means a fixed place of business