Debates Parlamentares - Diário 102S1, p. 75 (2012-01-20)

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

I It is understood that the terin "services rendered in the other Contracting State" shall be interpreted in the sense that the services are performed by an individual who is present in that other Contracting State, or by a company, through employees or other personnel engaged for such purpose who are present in that other State.
4 - e.
It is also understood that after a period of five years following the entering into force of the Convention, the competent authorities of the Contracting States inay evaluate the effectiveness of Article 14 of the Convention, with the view of ainending it, if necessary.
4. In relation with Article 6 The provisions of Article 6 of the Convention shall also apply to income from movable property, or income derived from services connected with the use or the right to use the immovable property, either of which, under the taxation law of the Contracting State in which the property is situated, is assimilated to income from immovable property.
8. In relation with Article 25 a) It is understood that information will only be requested once the requesting Contracting State has exhausted a11 regular sources of inforination available under the interna1 taxation procedure.
5. In relation with Article 10, paragraph 3 b) It is understood that the administrative assistance provided for in Article 25 does not include (i) measures aimed only at the simple collection of pieces of evidence, or (ii) when it is improbable that the requested information will be relevant for controlling or administering tax matters of a given taxpayer in a Contracting State.
31 7 In the case of Portugal, the tem "dividends" shall also include profits attributed under an arrangement for participation in profits ("associação em participação").
6. In relation with Article 12, paragraph 3 Payments in relation to software shall fall within the definition of "royalties" where less than the full rights to the software are transferred either if the payments are in consideration for the right to use a copyright on software for commercial exploitation (except payments for the right to distribute standardised software copies, not comprising the right either to custoinize nor to reproduce them) or if they relate to software acquired for the business use of the purchaser, when, in this last case, the software is not absolutely standardised but somehow adapted to the purchaser.
7. In relation with Article 14

75 | II Série A - Número: 102S1 | 20 de Janeiro de 2012I It is understood that the terin "services rendered in the other Contracting State" shall be interpreted in the sense that the services are performed by an individual who is present in that other Contracting State, or by a company, through employees or other personnel engaged for such purpose who are present in that other State.
4 - e.
It is also understood that after a period of five years following the entering into force of the Convention, the competent authorities of the Contracting States inay evaluate the effectiveness of Article 14 of the Convention, with the view of ainending it, if necessary.
4. In relation with Article 6 The provisions of Article 6 of the Convention shall also apply to income from movable property, or income derived from services connected with the use or the right to use the immovable property, either of which, under the taxation law of the Contracting State in which the property is situated, is assimilated to income from immovable property.
8. In relation with Article 25 a) It is understood that information will only be requested once the requesting Contracting State has exhausted a11 regular sources of inforination available under the interna1 taxation procedure.
5. In relation with Article 10, paragraph 3 b) It is understood that the administrative assistance provided for in Article 25 does not include (i) measures aimed only at the simple collection of pieces of evidence, or (ii) when it is improbable that the requested information will be relevant for controlling or administering tax matters of a given taxpayer in a Contracting State.
31 7 In the case of Portugal, the tem "dividends" shall also include profits attributed under an arrangement for participation in profits ("associação em participação").
6. In relation with Article 12, paragraph 3 Payments in relation to software shall fall within the definition of "royalties" where less than the full rights to the software are transferred either if the payments are in consideration for the right to use a copyright on software for commercial exploitation (except payments for the right to distribute standardised software copies, not comprising the right either to custoinize nor to reproduce them) or if they relate to software acquired for the business use of the purchaser, when, in this last case, the software is not absolutely standardised but somehow adapted to the purchaser.
7. In relation with Article 14

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