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

2. Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration paid by, or out of funds created by, a Contracting State or a political or administrative subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. However, such pensions and other similar remuneration shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.
3. The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, wages, pensions, and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political or administrative subdivision or a local authority thereof.
ARTICLE 20 STUDENTS Payments which a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.

ARTICLE 21 OTHER INCOME

Items of income of a resident of a Contracting State not dealt with in the foregoing articles of this Convention and arising in the other Contracting State may also be taxed in that other State.

CHAPTER IV METHODS FOR ELIMINATION OF DOUBLE TAXATION ARTICLE 22 ELIMINATION OF DOUBLE TAXATION 1. In Portugal double taxation shall be eliminated as follows: Where a resident of Portugal derives income which, in accordance with the provisions of this Convention, may be taxed in Colombia, Portugal shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Colombia. Such deduction shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable to the income which may be taxed in Colombia.
2. In Colombia, double taxation shall be avoided as follows: Where a resident of Colombia derives income which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, Colombia shall allow, subject to the limitations of provided for by its domestic law, a deduction from the income tax effectively paid by such resident in an amount equal to the income tax paid in Portugal. Such deduction shall not, however, exceed that part of the tax on the income as computed before the deduction is given, which is attributable to such items of income which may be taxed in that other Contracting State. In the case of dividends, Colombia shall allow a deduction from the income tax equal to the product of multiplying the total amount of the dividends by the income tax rate applicable to the profits from which such dividends are paid. When such dividends are taxed in the other Contracting State, this deduction will increase by the amount of such tax. However, this deduction shall not exceed the total amount of income tax payable in Colombia with respect to such dividends.
3. Where in accordance with any provisions of this Convention income derived by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.