CONVENTION BETWEEN THE REPUBLIC OF PERU AND THE PORTUGUESE REPUBLIC FOR THE AVOIDANCE OF DOUBLE

TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

The Republic of Peru and the Portuguese Republic, Desiring to conclude a Convention for the Avoidance of Double Taxation and the Pre-vention of Fiscal Evasion with respect to Taxes on Income, in order to promote and strengthen the economic relations between the two countries, Have agreed as follows:

CHAPTER I SCOPE OF THE CONVENTION

ARTICLE 1

PERSONS COVERED This Convention shall apply to persons who are residents of one or both of the Contracting States.

ARTICLE 2 TAXES COVERED

1. This Convention shall apply to taxes on income imposed on behalf of a Con-tracting Stateand, in the case of Portugal, on behalf of its political or administrative subdivisions or local authorities as well,irrespective of the manner in which they are levied. 2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or im-movable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation. 3. The existing taxes to which this Convention shall apply are in particular:

a) in the case of Portugal:

(i) the personal income tax (Imposto sobre o Rendimento das Pessoas Singulares – IRS);

(ii) the corporate income tax (Imposto sobre o Rendimento das Pessoas

Colectivas – IRC); and

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