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

At the moment of signing the Convention for &e Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income, this day concluded be- tween the United Arab Emirates aod thè-Paguese Republic, the undersigned have agreed that the following provisions shall foim an integral part of the Convention: 1. Ad Article 13 For the purpose of the interpretation of Article 13, it is understood that Article 13 (5) includes capital gains from the alienation of shares or comparable interest in a company, other than those referred to in Article 13 (4), derived by a resident of a Con- tracting state, including the government financia1 institutions or investment companies of that State.
2. Ad Article 24 It is agreed that Article 24 of the Convention shall not be construed to prevent either Contracting State from granting special treatment for its own national legal and natural entities.
3. With reference to the Convention Notwithstanding any other provisions of the Convention, except Articles 25 (Mutual Agreement Procedure) and 26 (Exchange of Information), income and profits of an enterprise of a Contracting State fiom the exploration and exploitation of natural resources in the other Contracting State shall be taxable only in that other State.
IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol.
DONE in duplicate at Abu Dhabi this 17 day of January, 201 1, in the Arabic, Portu- guese and English languages, a11 texts being equally authentic. In case of any diver- gente of interpretation of the text of this Protocol, the English text shall prevail.
FOR THE PORTUGUESE REPUBLIC FOR THE UNITED ARAB EMIRATES =+- LUIS A OBAID HUMAID AL TAYER Minister of State and of Foreign Affairs Minister of State For Financia1 Affairs 22 II SÉRIE-A — NÚMERO 95
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