Debates Parlamentares - Diário 105S2, p. 68 (2011-03-16)

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68 | II Série A - Número: 105S2 | 16 de Março de 2011

CONVENTION BETWEEN THE PORTUGUESE REPUBLIC AND THE REPUBLIC OF PANAMA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Portuguese Republic and the Republic of Panama, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in order to promote and strengthen the economic relations between the two countries, have agreed as follows: CHAPTER I SCOPE OF THE CONVENTION

ARTICLE 1 PERSONS COVERED

This Convention shall apply to persons who are residents of one or both of the Contracting States.

ARTICLE 2 TAXES COVERED

1. This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political or administrative subdivisions or local authorities, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.
3. The existing taxes to which the Convention shall apply are in particular:

a) in Panama:

the income tax provided in the Código Fiscal, Libro IV, Título I, and its related decrees and regulations.
(hereinafter referred to as ―Panamanian tax‖);

b) in Portugal:

(i) the personal income tax (Imposto sobre o Rendimento das Pessoas Singulares – IRS); (ii) the corporate income tax (Imposto sobre o Rendimento das Pessoas Colectivas – IRC); and (iii) the local surtax on corporate income tax (Derrama);

(hereinafter referred to as ―Portuguese tax‖).

4. The Convention shall apply also to any identical or substantially similar taxes that 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 significant changes that have been made in their taxation laws.

68 | II Série A - Número: 105S2 | 16 de Março de 2011CONVENTION BETWEEN THE PORTUGUESE REPUBLIC AND THE REPUBLIC OF PANAMA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Portuguese Republic and the Republic of Panama, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in order to promote and strengthen the economic relations between the two countries, have agreed as follows: CHAPTER I SCOPE OF THE CONVENTIONARTICLE 1 PERSONS COVEREDThis Convention shall apply to persons who are residents of one or both of the Contracting States.ARTICLE 2 TAXES COVERED1. This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political or administrative subdivisions or local authorities, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.
3. The existing taxes to which the Convention shall apply are in particular:a) in Panama:the income tax provided in the Código Fiscal, Libro IV, Título I, and its related decrees and regulations.
(hereinafter referred to as ―Panamanian tax‖);b) in Portugal:(i) the personal income tax (Imposto sobre o Rendimento das Pessoas Singulares – IRS); (ii) the corporate income tax (Imposto sobre o Rendimento das Pessoas Colectivas – IRC); and (iii) the local surtax on corporate income tax (Derrama);(hereinafter referred to as ―Portuguese tax‖).4. The Convention shall apply also to any identical or substantially similar taxes that 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 significant changes that have been made in their taxation laws.

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