Debates Parlamentares - Diário 027, p. 458 (1996-03-07)

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458

n SÉRIE-A — NÚMERO 27

CHAPTER VI Final provisions

Article 28

Entry into force

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

2 — This Convention shall enter into force on the date, of the exchange of ratification instruments and shall apply:

a) In Bulgaria:

0 In respect of taxes withheld at source, to amounts of income derived on or after 1 January in the.calendar year next following the year in' which the Convention enters into force;

ii) In respect of other taxes on income, to such taxs chargeable for any taxable year beginning on or after 1 January in the calendar year next following the year in which the Convention enters into force;

b) In Portugal:

0 In respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of January in the year next following the year in which this Convention enters into force; ' ii) In respect of other taxes as to income arising in any fiscal year beginning on or after the first day of January in the year next following the year in which this Convention enters into force.

Article 29 Termination

This Convention shall remain in force until terminated by one of the Contracting States. 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 following after the period of five years from the date on which the Convention enters into force. In such event the Convention shall cease to have effect:

a) In Bulgaria:

0 In respect of taxes withheld at source, to amounts of income derived on or after 1 January in the calendar year next following the year in which the notice is given;

it) In respect of other taxes on income, to such taxes chargeable for any taxable year beginning on or after 1 January in the calendar year next following the year in which the notice is given;

b) In Portugal:

i) In respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of January next following the date on which the period specified in the said notice of termination expires;

ii) In respect of other taxes as to income arising in the fiscal year beginning on or

■-• after the first day of January next following the date on which the period specified in the said notice of termination expires.

In witness whererof, the undersigned, duly authorized thereto, have signed this Convention.

Done in duplicate at Sofia, this fifteen day of June of 1995 in the Portuguese, Bulgarian and English languages.

In case of divergence of interpretation or application, the English text shall prevail.

For the Portuguese Republic: For the Republic of Bulgaria:

protocol

At the signing today of the Convention between the Portuguese Republic and the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, the Contracting States have agreed upon the following provisions, which shall form an integral part of the Convention:

1 —With reference to article 4, paragraph 1

Any person who is a national of Bulgaria and a resident of a third country, and who derives income from Portuguese source shall not enjoy the benefits provided for under this Convention.

2—With reference to article 10, paragraph 4

0 In the case of Portugal, privileged shares mean those shares giving their holder a preference, either as to receipt of dividends, or as to payment in case of winding up, or both. They comprise, namely, jouissance shares or jouissance rights, mining shares and founders' shares.

it) The provisions of this article shall also apply to income paid to a person associated to a business activity carried out by another person under an arrangement for participation in income as laid down by the laws of each Contracting State (in case of Portugal, associação em participação).

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

For the Portuguese Republic: For die Republic of Bulgaria:

458n SÉRIE-A — NÚMERO 27CHAPTER VI Final provisionsArticle 28Entry into force1 — This Convention shall be ratified and the instruments of ratification shall be exchanged at... as soon as possible.2 — This Convention shall enter into force on the date, of the exchange of ratification instruments and shall apply:a) In Bulgaria:0 In respect of taxes withheld at source, to amounts of income derived on or after 1 January in the.calendar year next following the year in' which the Convention enters into force;ii) In respect of other taxes on income, to such taxs chargeable for any taxable year beginning on or after 1 January in the calendar year next following the year in which the Convention enters into force;b) In Portugal:0 In respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of January in the year next following the year in which this Convention enters into force; ' ii) In respect of other taxes as to income arising in any fiscal year beginning on or after the first day of January in the year next following the year in which this Convention enters into force.Article 29 TerminationThis Convention shall remain in force until terminated by one of the Contracting States. 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 following after the period of five years from the date on which the Convention enters into force. In such event the Convention shall cease to have effect:a) In Bulgaria:0 In respect of taxes withheld at source, to amounts of income derived on or after 1 January in the calendar year next following the year in which the notice is given;it) In respect of other taxes on income, to such taxes chargeable for any taxable year beginning on or after 1 January in the calendar year next following the year in which the notice is given;b) In Portugal:i) In respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of January next following the date on which the period specified in the said notice of termination expires;ii) In respect of other taxes as to income arising in the fiscal year beginning on or■-• after the first day of January next following the date on which the period specified in the said notice of termination expires.In witness whererof, the undersigned, duly authorized thereto, have signed this Convention.Done in duplicate at Sofia, this fifteen day of June of 1995 in the Portuguese, Bulgarian and English languages.In case of divergence of interpretation or application, the English text shall prevail.For the Portuguese Republic: For the Republic of Bulgaria:protocolAt the signing today of the Convention between the Portuguese Republic and the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, the Contracting States have agreed upon the following provisions, which shall form an integral part of the Convention:1 —With reference to article 4, paragraph 1Any person who is a national of Bulgaria and a resident of a third country, and who derives income from Portuguese source shall not enjoy the benefits provided for under this Convention.2—With reference to article 10, paragraph 40 In the case of Portugal, privileged shares mean those shares giving their holder a preference, either as to receipt of dividends, or as to payment in case of winding up, or both. They comprise, namely, jouissance shares or jouissance rights, mining shares and founders' shares.it) The provisions of this article shall also apply to income paid to a person associated to a business activity carried out by another person under an arrangement for participation in income as laid down by the laws of each Contracting State (in case of Portugal, associação em participação).In witness whereof, the undersigned, duly authorized thereto, have signed this Protocol.For the Portuguese Republic: For die Republic of Bulgaria:

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