Debates Parlamentares - Diário 102S1, p. 60 (2012-01-20)

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

ASSOCIATED ENTERPRISES 1. Where: 2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a "pool", consortium, joint venture or a similar form of association, or in an international organization or agency engaged in international traffic, but only with regard to the share of the profits attributable to each participant proportionally to its participation.
a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are inade or imposed between the two enterprises in their coinmercial or financia1 relations which differ from those which would be inade between independent enterprises, then any profits which would, but for tliose conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State, if it agrees that the adjustment made by the first-mentioned State is justified both in principle and as regards the amount, shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Convention and the coinpetent authorities of the Contracting States shall, if necessary, consult each other.
ARTICLE 10 DIVIDENDS 1. Dividends paid by a coinpany which is a resident of a Contracting State to a resident of the other Contracting State inay be taxed in that other State.
II SÉRIE-A — NÚMERO 102
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60

Consultar Diário Original

60 | II Série A - Número: 102S1 | 20 de Janeiro de 2012ASSOCIATED ENTERPRISES 1. Where: 2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a "pool", consortium, joint venture or a similar form of association, or in an international organization or agency engaged in international traffic, but only with regard to the share of the profits attributable to each participant proportionally to its participation.
a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are inade or imposed between the two enterprises in their coinmercial or financia1 relations which differ from those which would be inade between independent enterprises, then any profits which would, but for tliose conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State, if it agrees that the adjustment made by the first-mentioned State is justified both in principle and as regards the amount, shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Convention and the coinpetent authorities of the Contracting States shall, if necessary, consult each other.
ARTICLE 10 DIVIDENDS 1. Dividends paid by a coinpany which is a resident of a Contracting State to a resident of the other Contracting State inay be taxed in that other State.
II SÉRIE-A — NÚMERO 102
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60
Consultar Diário Original

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