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

the notification as referred to in subparagraph c) of this paragraph; and

(bb) with respect to other taxes, as to interest arising in any taxable year beginning on or after the first day of January of the calendar year next following the thirtieth day after the date of receipt of the notification as referred to in subparagraph c) of this paragraph; and
(ii) in the case of Japan:

(aa) with respect to taxes withheld at source on interest, for amounts taxable on or after 1 January in the calendar year next following the thirtieth day after the date of receipt of the notification as referred to in subparagraph c) of this paragraph; and

(bb) with respect to taxes on interest which are not withheld at source, as regards interest for any taxable year beginning on or after 1 January in the calendar year next following the thirtieth day after the date of receipt of the notification as referred to in subparagraph c) of this paragraph;

c) Portugal shall send Japan through diplomatic channels without delay the notification confirming the entry into force of such an agreement.
10. Notwithstanding the provisions of paragraph 5 of Article 13 of the Convention, a) Where

(i) a Contracting State (including, for this purpose in the case of Japan, the Deposit Insurance Corporation of Japan) provides, pursuant to the laws of that Contracting State concerning failure resolution involving imminent insolvency of financial institutions, substantial financial assistance to a financial institution that is a resident of that Contracting State, and

(ii) a resident of the other Contracting State acquires shares in the financial institution from the first-mentioned Contracting State, the first-mentioned Contracting State may tax gains derived by the resident of the other Contracting State from the alienation of such shares, provided that the alienation is made within five years from the first date on