Debates Parlamentares - Diário 146S1, p. 48 (2012-03-21)

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48 | II Série A - Número: 146S1 | 21 de Março 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 PROFESSORS AND RESEARCHERS
An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State, solely for the purpose of teaching or scientific research at an university, college, school, or other similar educational or scientific research institution which is recognized as non-profitable by the Government of that other State, or under an official programme of cultural exchange, for a period not exceeding two years from the date of his first arrival in that other State, shall be exempt from tax in that other State on his remuneration for such teaching or research. ARTICLE 21 STUDENTS AND TRAINEES

1. Payments which a student or trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present temporarily 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. 2. Payments which the student or trainee receives during his presence the firstmentioned State solely for his maintenance or for acquiring technical or professional experience shall be exempt from tax by that State during a period of two years if its aggregate amount doesn't exceed nine thousand dollars (USD 9,000) and the traineeship is directly connected with his studies. ARTICLE 22 OFFSHORE & ONSHORE ACTIVITIES

1. The provisions of this Article shall apply notwithstanding any other provision of this Convention.

2. A person who is a resident of a Contracting State and carries on activities offshore & onshore in the other Contracting State in connection with the exploration or exploita

48 | II Série A - Número: 146S1 | 21 de Março de 20122. 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 PROFESSORS AND RESEARCHERS
An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State, solely for the purpose of teaching or scientific research at an university, college, school, or other similar educational or scientific research institution which is recognized as non-profitable by the Government of that other State, or under an official programme of cultural exchange, for a period not exceeding two years from the date of his first arrival in that other State, shall be exempt from tax in that other State on his remuneration for such teaching or research. ARTICLE 21 STUDENTS AND TRAINEES1. Payments which a student or trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present temporarily 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. 2. Payments which the student or trainee receives during his presence the firstmentioned State solely for his maintenance or for acquiring technical or professional experience shall be exempt from tax by that State during a period of two years if its aggregate amount doesn't exceed nine thousand dollars (USD 9,000) and the traineeship is directly connected with his studies. ARTICLE 22 OFFSHORE & ONSHORE ACTIVITIES1. The provisions of this Article shall apply notwithstanding any other provision of this Convention.2. A person who is a resident of a Contracting State and carries on activities offshore & onshore in the other Contracting State in connection with the exploration or exploita

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