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

in the other Contracting State; and

(ii) treated as the income 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 to a resident of that other Contracting State, without regard to whether the income is treated as the income of that entity under the tax laws of the first-mentioned Contracting State, if such entity is a resident of that other Contracting State and satisfies any other conditions specified in the Convention.

c) an item of income:

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

(ii) treated as the income of that entity under the tax laws of the other Contracting State;

shall not be eligible for the benefits of the Convention. 3. With reference to Article 6 of the Convention:
Income from immovable property includes income from any property other than immovable property connected with the use or the right to use the immovable property, or income derived from services for the maintenance or operation of the immovable property, either of which is subject to the same taxation treatment as income from immovable property by the tax laws of the Contracting State in which the immovable property is situated.
4. With reference to paragraph 2 of Article 8 of the Convention, if Portugal introduces any tax similar to the enterprise tax of Japan, Portugal shall send Japan through diplomatic channels without delay the notification confirming the entry into force of its domestic laws concerning that tax. In this case, the Contracting States shall agree on how that paragraph has effect and ceases to have effect.
5. Notwithstanding any provisions of the Convention, any income and gains derived by a silent partner in respect of a silent partnership (in the case of Japan, Tokumei Kumiai and, in the case of Portugal, associação em participação) contract or other similar con