Debates Parlamentares - Diário 102S1, p. 55 (2012-01-20)

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55 | II Série A - Número: 102S1 | 20 de Janeiro de 2012

(ii) in Portugal: the Minister of Finance, the Director General of Taxation (Director-Geral dos Impostos) or their authorised representative; . - I1 j) the term "nationalYy, in relation to a Contracting State, means: h) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; i) the term "competent authority" means: (i) in Panama, the Ministry of Economy and Finance (Ministerio de Economía y Finanzas) or its authorized representative; (i) any individual possessing the nationality or citizenship of that Contracting State; and (ii) any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State.
1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: I, J 4 a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permánent home available to him in both States, he shall be deemed to be a resident only of the State 2. As regards the application of the Convention at any time by a Contracting State, any terin not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.
ARTICLE 4 RESIDENT with which his personal and econoinic relations are closer (centre of vital interests); b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either

55 | II Série A - Número: 102S1 | 20 de Janeiro de 2012(ii) in Portugal: the Minister of Finance, the Director General of Taxation (Director-Geral dos Impostos) or their authorised representative; . - I1 j) the term "nationalYy, in relation to a Contracting State, means: h) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; i) the term "competent authority" means: (i) in Panama, the Ministry of Economy and Finance (Ministerio de Economía y Finanzas) or its authorized representative; (i) any individual possessing the nationality or citizenship of that Contracting State; and (ii) any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State.
1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature, and also includes that State and any political or administrative subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.
2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: I, J 4 a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permánent home available to him in both States, he shall be deemed to be a resident only of the State 2. As regards the application of the Convention at any time by a Contracting State, any terin not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.
ARTICLE 4 RESIDENT with which his personal and econoinic relations are closer (centre of vital interests); b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either

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