Debates Parlamentares - Diário 116S1, p. 40 (2012-02-08)

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

In the case of Colombia, subject to the provisions of paragraph 2 of Article 10 of the Convention, when a company which is a resident of Colombia has not paid income tax on profits distributed to shareholders (socios o accionistas) because of exemptions or because the profit exceeds the non taxed limit contained in article 49 and in paragraph 1 of the Article 245 of the Tax Statute, the dividend distributed may be taxed in Colombia at a rate of 33 %, if the beneficial owner of the dividend is a shareholder (socio o accionista) resident of Portugal. 5. In relation to Article 12 a) If, after the signing of the Convention, Colombia concludes with a third state a Convention which includes provisions regarding technical assistance, technical services or consulting services that are more favorable than those provided for in Article 12 of the Convention, such provisions shall apply automatically to the Convention, under the same conditions as if they had been included in the Convention. Such provisions shall apply to the Convention from the date of entry into force of the Convention with the third State. The competent authority of Colombia shall inform the competent authority of Portugal without delay that the conditions of application of this paragraph have been fulfilled.
b) In relation to paragraph 3 of Article 12 it is agreed that the term “royalties” also includes gains derived from the alienation of the rights or property mentioned in paragraph 3 of Article 12 of the Convention to the extent that such gains are contingent on the productivity, use, or disposition thereof.

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

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
II SÉRIE-A — NÚMERO 116
_________________________________________________________________________________________________________________
40

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40 | II Série A - Número: 116S1 | 8 de Fevereiro de 2012In the case of Colombia, subject to the provisions of paragraph 2 of Article 10 of the Convention, when a company which is a resident of Colombia has not paid income tax on profits distributed to shareholders (socios o accionistas) because of exemptions or because the profit exceeds the non taxed limit contained in article 49 and in paragraph 1 of the Article 245 of the Tax Statute, the dividend distributed may be taxed in Colombia at a rate of 33 %, if the beneficial owner of the dividend is a shareholder (socio o accionista) resident of Portugal. 5. In relation to Article 12 a) If, after the signing of the Convention, Colombia concludes with a third state a Convention which includes provisions regarding technical assistance, technical services or consulting services that are more favorable than those provided for in Article 12 of the Convention, such provisions shall apply automatically to the Convention, under the same conditions as if they had been included in the Convention. Such provisions shall apply to the Convention from the date of entry into force of the Convention with the third State. The competent authority of Colombia shall inform the competent authority of Portugal without delay that the conditions of application of this paragraph have been fulfilled.
b) In relation to paragraph 3 of Article 12 it is agreed that the term “royalties” also includes gains derived from the alienation of the rights or property mentioned in paragraph 3 of Article 12 of the Convention to the extent that such gains are contingent on the productivity, use, or disposition thereof.IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol.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
II SÉRIE-A — NÚMERO 116
_________________________________________________________________________________________________________________
40
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