Debates Parlamentares - Diário 102S1, p. 68 (2012-01-20)

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

3. Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing articles of this Convention and arising in the other Contracting State rnay also be taxed in that other State.
I CHAPTER IV METHODS FOR ELIMINATION OF DOUBLE TAXATION respect of which the income is paid is effectively connected with such perinanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case rnay be, shall apply.
ARTICLE 22 ELIMINATION OF DOUBLE TAXATION 1. In Panama, double taxation shall be eliminated as follows: 1 Where a resident of Panama derives income which, in accordance with the provisions of this Convention, rnay be taxed in Portugal, Panama will exempt such income frorn taxes.
2. In Portugal, double taxation shall be eliminated as follows: ii Where a resident of Portugal derives incoine which, in accordance with the provisions of this Convention, rnay be taxed in Panama, Portugal shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Panama. 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 rnay be taxed in Panama.
3. Where in accordance with any provisions of this Convention income derived by a resident of a Contracting State is exeinpt froin tax in that State, such State rnay nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
CHAPTER V SPECIAL PROVISIONS ARTICLE 23 NON DISCRIMINATION 1 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 circumstances, in particular with respect to residence, are or rnay 16

68 | II Série A - Número: 102S1 | 20 de Janeiro de 20123. Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing articles of this Convention and arising in the other Contracting State rnay also be taxed in that other State.
I CHAPTER IV METHODS FOR ELIMINATION OF DOUBLE TAXATION respect of which the income is paid is effectively connected with such perinanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case rnay be, shall apply.
ARTICLE 22 ELIMINATION OF DOUBLE TAXATION 1. In Panama, double taxation shall be eliminated as follows: 1 Where a resident of Panama derives income which, in accordance with the provisions of this Convention, rnay be taxed in Portugal, Panama will exempt such income frorn taxes.
2. In Portugal, double taxation shall be eliminated as follows: ii Where a resident of Portugal derives incoine which, in accordance with the provisions of this Convention, rnay be taxed in Panama, Portugal shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Panama. 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 rnay be taxed in Panama.
3. Where in accordance with any provisions of this Convention income derived by a resident of a Contracting State is exeinpt froin tax in that State, such State rnay nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
CHAPTER V SPECIAL PROVISIONS ARTICLE 23 NON DISCRIMINATION 1 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 circumstances, in particular with respect to residence, are or rnay 16

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