Debates Parlamentares - Diário 095S1, p. 40 (2012-01-11)

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

3. The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, wages, pen- sions, and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political or administrative subdivision or a local government or other local authority thereof.
ARTICLE 20 PROFESSORS AND RESEARCHERS An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State, solely for the purpose of teaching or scientific re- search at an university, college, school, or other similar educational or scientific re- search institution which is recognized as non-profitable by the Governrnent of that other State, or under an official prograrnrne of cultural exchange, for a period not exceeding three years fiom the date of his first arrival in that other State, shall be exempt fiom tax in that other State on his remuneration for such teaching or research.
ARTICLE 2 1 STUDENTS Payments which a student or business apprentice who is or was irnmediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise fiom sources outside that State.
ARTICLE 22 OTHER NCOME 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than income fiom irnrnovable property as defined in paragraph 2 of Article 6, if the recipient of such in- come, being a resident of a Contracting State, carries on business in the other Contract- ing State through a permanent establishment situated therein, or perforrns in that other State independent personal services fiom a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such per- manent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
3. Where, by reason of a special relationship between the person refened to in paragraph 1 and some other person, or between both of them and some third person, the amount of the income refened to in paragraph 1 exceeds the amount (if any) which would have been agreed upon between them in the absence of such a relationship, the provisions of this Article shall apply only to the last mentioned amount. In such a case, the excess part of the income shall remain taxable according to the laws of each Con-

40 | II Série A - Número: 095S1 | 11 de Janeiro de 20123. The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, wages, pen- sions, and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political or administrative subdivision or a local government or other local authority thereof.
ARTICLE 20 PROFESSORS AND RESEARCHERS An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State, solely for the purpose of teaching or scientific re- search at an university, college, school, or other similar educational or scientific re- search institution which is recognized as non-profitable by the Governrnent of that other State, or under an official prograrnrne of cultural exchange, for a period not exceeding three years fiom the date of his first arrival in that other State, shall be exempt fiom tax in that other State on his remuneration for such teaching or research.
ARTICLE 2 1 STUDENTS Payments which a student or business apprentice who is or was irnmediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise fiom sources outside that State.
ARTICLE 22 OTHER NCOME 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than income fiom irnrnovable property as defined in paragraph 2 of Article 6, if the recipient of such in- come, being a resident of a Contracting State, carries on business in the other Contract- ing State through a permanent establishment situated therein, or perforrns in that other State independent personal services fiom a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such per- manent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
3. Where, by reason of a special relationship between the person refened to in paragraph 1 and some other person, or between both of them and some third person, the amount of the income refened to in paragraph 1 exceeds the amount (if any) which would have been agreed upon between them in the absence of such a relationship, the provisions of this Article shall apply only to the last mentioned amount. In such a case, the excess part of the income shall remain taxable according to the laws of each Con-

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