Debates Parlamentares - Diário 102S1, p. 64 (2012-01-20)

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

5. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State rnay be taxed in that other State.
- - 6. Gains fiom the alienation of any property other than that referred to in the preceding paragraphs shall be taxable only in the Contracting State of which the alienator is a resident.
ARTICLE 13 CAPITAL GAINS 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State rnay be taxed in that other State.
2. Gains from the alienation of movable property forming part of the business ARTICLE 14 SERVICES 1. Income derived by a resident of a Contracting State for services rendered in the other Contracting State rnay be taxed in the first-mentioned State. However, such income rnay also be taxed in the Contracting State where the services were rendered, to the extent that such services qualify as professional services, consulting services, industrial or commercial advice, technical or management services or similar services, but if the beneficia1 owner of such income is a resident of the other Contracting State, the tax so charged rnay not exceed 10 per cent of the gross amount of such income.
C';.
I property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of inovable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, rnay be taxed in that other State.
3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State.
4. Gains derived by a resident of a Contracting State from the alienation of shares or coinparable interests representing the capital of a company that is a resident of the other Contracting State rnay be taxed in that other Contracting State if such shares or comparable interests represent 25% or more of the capital of that company, but the tax so charged shall not exceed either 5% of their alienation value or 10% of the net amount of such gains.

64 | II Série A - Número: 102S1 | 20 de Janeiro de 20125. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State rnay be taxed in that other State.
- - 6. Gains fiom the alienation of any property other than that referred to in the preceding paragraphs shall be taxable only in the Contracting State of which the alienator is a resident.
ARTICLE 13 CAPITAL GAINS 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State rnay be taxed in that other State.
2. Gains from the alienation of movable property forming part of the business ARTICLE 14 SERVICES 1. Income derived by a resident of a Contracting State for services rendered in the other Contracting State rnay be taxed in the first-mentioned State. However, such income rnay also be taxed in the Contracting State where the services were rendered, to the extent that such services qualify as professional services, consulting services, industrial or commercial advice, technical or management services or similar services, but if the beneficia1 owner of such income is a resident of the other Contracting State, the tax so charged rnay not exceed 10 per cent of the gross amount of such income.
C';.
I property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of inovable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, rnay be taxed in that other State.
3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State.
4. Gains derived by a resident of a Contracting State from the alienation of shares or coinparable interests representing the capital of a company that is a resident of the other Contracting State rnay be taxed in that other Contracting State if such shares or comparable interests represent 25% or more of the capital of that company, but the tax so charged shall not exceed either 5% of their alienation value or 10% of the net amount of such gains.

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