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100 | II Série A - Número: 116S1 | 8 de Fevereiro de 2012

2. Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting Party in which the activities of the entertainer or sportsman are exercised.

Article 18 Pensions

1. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration (including a lump sum payment) paid to a resident of a Contracting Party in consideration of past employment or self-employment shall be taxable only in that Party.

2. Notwithstanding the provisions of paragraph 1, payments made under a mandatory provident fund scheme in a Contracting Party, and any other similar schemes or arrangements which may be established in that Party to replace that scheme, may be taxed in that Party. Article 19 Government Service

1. Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting Party or a political or administrative subdivision or a local authority thereof to an individual in respect of services rendered to that Party or subdivision or authority shall be taxable only in that Party. However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting Party if the services are rendered in that Party and the individual is a resident of that Party who:

(a) in the case of the Hong Kong Special Administrative Region, has the right of abode therein and in the case of Portugal, is a national thereof; or

(b) did not become a resident of that Party solely for the purpose of rendering the services.

2. Any pension (including a lump sum payment) paid by, or paid out of funds created or contributed by, a Contracting Party or a political or administrative subdivision or a local authority thereof to an individual in respect of services rendered to that Party or subdivision or authority shall be taxable only in that Party. However, such pensions (whether a payment in lump sum or by instalments) shall be taxable only in the other Contracting Party if the services were rendered in that Party and the individual is a resident of that Party, and that the case falls within subparagraph (a) or (b) of paragraph 1 of this Article.

3. The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages, pensions (including a lump sum payment), and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting Party or a political or administrative subdivision or a local authority thereof.