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

PROTOCOL TO THE CONVENTION BETWEEN THE PORTUGUESE REPUBLIC AND JAPAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
At the signing of the Convention between the Portuguese Republic and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (hereinafter referred to as “the Convention”), the Portuguese Republic and Japan have agreed upon the following provisions, which shall form an integral part of the Convention: 1. The competent authorities of the Contracting States shall notify each other its internal procedures concerning the mode of application of the Convention.
2. For the purposes of applying the Convention:
a) an item of income:

(i) derived from a Contracting State through an entity that is organised in the other Contracting State; and

(ii) treated as the income of the beneficiaries, members or participants of that entity under the tax laws of that other Contracting State;
shall be eligible for the benefits of the Convention that would be granted if it were directly derived by a beneficiary, member or participant of that entity who is a resident of that other Contracting State, to the extent that such beneficiaries, members or participants are residents of that other Contracting State and satisfy any other conditions specified in the Convention, without regard to whether the income is treated as the income of such beneficiaries, members or participants under the tax laws of the first-mentioned Contracting State.

b) an item of income:

(i) derived from a Contracting State through an entity that is organised