Debates Parlamentares - Diário 116S1, p. 39 (2012-02-08)

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

first day of January of the calendar year next following that specified in the notice of termination.

IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Convention.
DONE in duplicate at Bogota, on the 30th of August of 2010, in the Portuguese, Spanish and English languages, all texts being equally authentic. In case of any divergence of interpretation of the text of this Convention, the English text shall prevail.

FOR THE PORTUGUESE REPUBLIC FOR THE REPUBLIC OF COLOMBIA
PROTOCOL TO THE CONVENTION BETWEEN THE PORTUGUESE REPUBLIC AND THE REPUBLIC OF COLOMBIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME On signing the Convention between the Portuguese Republic and the Republic of Colombia 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 signatories have agreed that the following provisions shall form an integral part of the Convention:

1. In relation to paragraph 3 of Article 5 For purposes of calculating the time limits set forth in paragraph 3 of Article 5 of the Convention, the activities carried on by an enterprise associated with another enterprise in terms of Article 9 of the Convention, shall be added to the time period of the activities carried out by the enterprise of which it is an associate, if the activities of both enterprises are identical or substantially similar and are carried out in connection with the same site or project.
2. In relation to paragraph 3 of Article 7 In applying paragraph 3 of Article 7 of the Convention, deductibility of expenses shall be determined in accordance with the domestic legislation of the Contracting State in which the permanent establishment is located, provided that the requirements, conditions, and limitations to which they are subjected, are complied with. 3. In relation to paragraph 3 of Article 8 It is agreed that whenever companies from different countries have agreed to carry on an air transportation business together in the form of a consortium or a similar form of association, the provisions of paragraph 1 of Article 8 of the Convention shall apply to such part of the profits of the consortium or association as corresponds to the participation held in that consortium or association by a company that is a resident of a Contracting State.

39 | II Série A - Número: 116S1 | 8 de Fevereiro de 2012first day of January of the calendar year next following that specified in the notice of termination.IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Convention.
DONE in duplicate at Bogota, on the 30th of August of 2010, in the Portuguese, Spanish and English languages, all texts being equally authentic. In case of any divergence of interpretation of the text of this Convention, the English text shall prevail.FOR THE PORTUGUESE REPUBLIC FOR THE REPUBLIC OF COLOMBIA
PROTOCOL TO THE CONVENTION BETWEEN THE PORTUGUESE REPUBLIC AND THE REPUBLIC OF COLOMBIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME On signing the Convention between the Portuguese Republic and the Republic of Colombia 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 signatories have agreed that the following provisions shall form an integral part of the Convention:1. In relation to paragraph 3 of Article 5 For purposes of calculating the time limits set forth in paragraph 3 of Article 5 of the Convention, the activities carried on by an enterprise associated with another enterprise in terms of Article 9 of the Convention, shall be added to the time period of the activities carried out by the enterprise of which it is an associate, if the activities of both enterprises are identical or substantially similar and are carried out in connection with the same site or project.
2. In relation to paragraph 3 of Article 7 In applying paragraph 3 of Article 7 of the Convention, deductibility of expenses shall be determined in accordance with the domestic legislation of the Contracting State in which the permanent establishment is located, provided that the requirements, conditions, and limitations to which they are subjected, are complied with. 3. In relation to paragraph 3 of Article 8 It is agreed that whenever companies from different countries have agreed to carry on an air transportation business together in the form of a consortium or a similar form of association, the provisions of paragraph 1 of Article 8 of the Convention shall apply to such part of the profits of the consortium or association as corresponds to the participation held in that consortium or association by a company that is a resident of a Contracting State.

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