Debates Parlamentares - Diário 095S1, p. 38 (2012-01-11)

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38 | II Série A - Número: 095S1 | 11 de Janeiro de 2012

taxed in the other Contracting State but only so much of it as is attributable to that fixed base.
2. The term "professional services" includes especially independent scientific, lit- erary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
ARTICLE 15 DEPENDENT PERSONAL SERVICES 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is de- rived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing State shall be taxable only in the first-mentioned State if: a) the recipient is present in the other State for a period or periods not ex- ceeding in the aggregate 183 days in any twelve month period cornrnenc- ing or ending in the fiscal year concemed, and b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircrafi operated in international traffic may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise is situated.
ARTICLE 16 DIRECTORS' FEES Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or supervisory board or of another similar organ of a company which is a resident of the other Contracting State may be taxed in that other State.

38 | II Série A - Número: 095S1 | 11 de Janeiro de 2012taxed in the other Contracting State but only so much of it as is attributable to that fixed base.
2. The term "professional services" includes especially independent scientific, lit- erary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
ARTICLE 15 DEPENDENT PERSONAL SERVICES 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is de- rived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing State shall be taxable only in the first-mentioned State if: a) the recipient is present in the other State for a period or periods not ex- ceeding in the aggregate 183 days in any twelve month period cornrnenc- ing or ending in the fiscal year concemed, and b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircrafi operated in international traffic may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise is situated.
ARTICLE 16 DIRECTORS' FEES Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or supervisory board or of another similar organ of a company which is a resident of the other Contracting State may be taxed in that other State.

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