Debates Parlamentares - Diário 095S1, p. 41 (2012-01-11)

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

CHAPTER IV METHODS FOR ELIMINATION OF DOUBLE TAXATION 1 ARTICLE 23 ELIMINATION OF DOUBLE TAXATION tracting State, due regard being had to the other applicable provisions of this Conven- tion.
1. Where a resident of a Contracting State derives income which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned State shall allow as a deduction from the tax on the income of that resi- dent, an amount equal to the income tax paid in that other State. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in that other State.
2. Where in accordance with any provision of this Convention income derived by a resident of a Contracting State is exempt fiom tax in that State, such State may never- theless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
CHAPTER V SPECIAL PROVISIONS ARTICLE 24 NON-DISCRIMINATION 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circurnstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also ap- ply to persons who are not residents of one or both of the Contracting States.
2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reduc- tions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
3. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall,

41 | II Série A - Número: 095S1 | 11 de Janeiro de 2012CHAPTER IV METHODS FOR ELIMINATION OF DOUBLE TAXATION 1 ARTICLE 23 ELIMINATION OF DOUBLE TAXATION tracting State, due regard being had to the other applicable provisions of this Conven- tion.
1. Where a resident of a Contracting State derives income which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned State shall allow as a deduction from the tax on the income of that resi- dent, an amount equal to the income tax paid in that other State. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in that other State.
2. Where in accordance with any provision of this Convention income derived by a resident of a Contracting State is exempt fiom tax in that State, such State may never- theless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
CHAPTER V SPECIAL PROVISIONS ARTICLE 24 NON-DISCRIMINATION 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circurnstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also ap- ply to persons who are not residents of one or both of the Contracting States.
2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reduc- tions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
3. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall,

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