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

a) in respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of January of the calendar year next following that in which this Convention enters into force; b) in respect of other taxes, as to income arising in any fiscal year beginning on or after the first day of January of the calendar year next following that in which this Convention enters into force; c) in respect of the exchange of information, the requests may be performed upon the date of entry into force for criminal tax matters; and also upon that date for all other matters but only in respect of taxable periods beginning on or after that date or, where there is no taxable period, all charges to tax arising on or after that date.

ARTICLE 29 DURATION AND TERMINATION

1. Following the expiration of an initial period of five years, this Convention shall remain in force for an unlimited period of time.
2. Following the expiration of the initial period of five years, either Contracting State may denounce this Convention upon notification, in writing through diplomatic channels, before the first day of July of the current calendar year. 3. In the event of denunciation, this Convention shall cease to have effect:

a) in respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of January of the calendar year next following that specified in the notice of termination; b) in respect of other taxes, as to income arising in the fiscal year beginning on or after the first day of January of the calendar year next following that specified in the notice of termination.

IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Convention.

DONE at Panama City, on the 27th of August of 2010, in duplicate, in the Portuguese, Spanish and English languages, the three texts being equally authentic. In case there is any divergence of interpretation between any of the texts of this Convention, the English text shall prevail.

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