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29 | II Série A - Número: 107S1 | 30 de Junho de 2010

b) Include information that is relevant to the determination, assessment and collection of such taxes, the recovery and enforcement of tax claims, or the investigation or prosecution of criminal tax matters; and c) Be treated as confidential as set forth in this Agreement.

2. With respect to paragraphs a) and b) of this Article information will be considered relevant notwithstanding that a definite assessment of the pertinence of the information to an on-going investigation could only be made following the receipt of the information.

Article 2.º Jurisdiction

A requested Party is not obligated to provide information which is neither held by its authorities nor in the possession or control of persons who are within its territorial jurisdiction.

Article 3.º Taxes covered

1. This Agreement shall apply to the following taxes imposed by the Parties:

a) In case of Portugal: i. Personal income tax (Imposto sobre o Rendimento das Pessoas Singulares – IRS); ii. Corporate income tax (Imposto sobre o Rendimento das Pessoas Colectivas – IRC); iii. Local surtax on corporate income tax (Derrama); iv. Stamp duty on gratuitous transfers (Imposto do Selo sobre as transmissões gratuitas).

b) In case of Bermuda:

i. Direct taxes of every kind and description.

2. This Agreement shall also apply to any identical taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes. This Agreement shall also apply to any substantially similar taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes if the competent authorities of the Parties so agree. Furthermore, the taxes covered may be expanded or modified by mutual agreement of the Parties in the form of an exchange of letters. The competent authorities of the Parties shall notify each other of any substantial changes to the taxation and related information gathering measures covered by the Agreement.

Article 4.º Definitions

1. In this Agreement:

a) ―Portugal,‖ means territory of the Portuguese Republic situated in the European continent, the archipelagos of Azores and Madeira, the territorial sea and inland waters thereof as well as the continental shelf and any other area wherein the Portuguese State exercises sovereign rights or jurisdiction in accordance with the rules of international law and the laws of the Portuguese Republic; b) ―Bermuda‖ means the Islands of Bermuda; c) ―Company‖ means any body corporate or any entity that is treated as a body corporate for tax purposes;