c) It is understood that the provisions of the Convention shall not apply if it was the main purpose or one of the main purposes of any person con-cerned 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;

d)Nothing in the Convention shall preclude the application of the provisions of Peruvian Law Acts (Decretos Legislativos) numbers 662, 757 and 109 and Acts (Leyes) numbers 26221, 27342, 27343, 27909 as they are in force at the time of the signature of the Convention and as they may be amended from time to time without changing their principle or the optional nature of entering into the tax stability contracts. A person that is a party to a contract which grants tax stability in accordance with the above-mentioned provision shall, notwithstanding any rate of tax set out in the Convention, remains subject to the rates of tax stabilized by the contract for its duration;

e) Notwithstanding any other international agreement (including the General Agreement on Trade in Services), any dispute between the Contracting States concerning a tax to which the Convention applies shall be subject only to the provisions of the Convention.

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

DONE in duplicate at Lisbon this 19 day of November 2012, in the Spanish, Portuguese 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.

A Divisão de Redação e Apoio Audiovisual.

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