Debates Parlamentares - Diário 116S1, p. 374 (2012-02-08)

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

PROTOCOL TO THE AGREEMENT BETWEEN THE PORTUGUESE REPUBLIC AND THE STATE OF QATAR FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
On signing the Agreement between the Portuguese Republic and the State of Qatar for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income the signatories have agreed that the following provisions shall form an integral part of the Agreement:

1. a) It is understood that the provisions of the Agreement shall not be interpreted so as to prevent the application by a Contracting State of the anti-avoidance provisions provided for in its domestic law;

b) It is understood that the benefits foreseen in the Agreement shall not be granted to a resident of a Contracting State which is not the beneficial owner of the income derived from the other Contracting State;

c) The provisions of the Agreement shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the property or right in respect of which the income is paid to take advantage of those provisions by means of such creation or assignment.

2. It is understood that the provision of subparagraph a) of paragraph 2 of Article 10, paragraph 3 of Article 11 and of the last sentence of paragraph 4 of Article 13 shall apply to Qatar Investment Authority and its affiliates including Qatar Holding and Qatari Diyar as long as they are wholly owned, directly or indirectly, by the Government of the State of Qatar, its political or administrative subdivisions or local authorities.

IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol.

DONE in duplicate at Doha this ________day of December, 2011, in the Portuguese, Arabic and English languages, all texts being equally authentic. In case of any divergence of interpretation of the text of this Protocol, the English text shall prevail.
FOR THE PORTUGUESE REPUBLIC: FOR THE STATE OF QATAR:

374 | II Série A - Número: 116S1 | 8 de Fevereiro de 2012PROTOCOL TO THE AGREEMENT BETWEEN THE PORTUGUESE REPUBLIC AND THE STATE OF QATAR FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
On signing the Agreement between the Portuguese Republic and the State of Qatar for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income the signatories have agreed that the following provisions shall form an integral part of the Agreement:1. a) It is understood that the provisions of the Agreement shall not be interpreted so as to prevent the application by a Contracting State of the anti-avoidance provisions provided for in its domestic law;b) It is understood that the benefits foreseen in the Agreement shall not be granted to a resident of a Contracting State which is not the beneficial owner of the income derived from the other Contracting State;c) The provisions of the Agreement shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the property or right in respect of which the income is paid to take advantage of those provisions by means of such creation or assignment.2. It is understood that the provision of subparagraph a) of paragraph 2 of Article 10, paragraph 3 of Article 11 and of the last sentence of paragraph 4 of Article 13 shall apply to Qatar Investment Authority and its affiliates including Qatar Holding and Qatari Diyar as long as they are wholly owned, directly or indirectly, by the Government of the State of Qatar, its political or administrative subdivisions or local authorities.IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol.DONE in duplicate at Doha this ________day of December, 2011, in the Portuguese, Arabic and English languages, all texts being equally authentic. In case of any divergence of interpretation of the text of this Protocol, the English text shall prevail.
FOR THE PORTUGUESE REPUBLIC: FOR THE STATE OF QATAR:

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