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PROTOCOL TO THE CONVENTION BETWEEN THE PORTU-

GUESE REPUBLIC AND GEORGIA FOR THE AVOIDANCE OF

DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVA-

SION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

On signing the Convention between the Portuguese Republic and Georgia for the

Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to

Taxes on Income and on Capital (hereinafter referred to as “the Convention”), the signa-tories have agreed that the following provisions shall form an integral part of the Con-

vention:

1. Entitlement to the Benefits foreseen in the Convention:

a) It is understood that the provisions of the Convention shall not be inter-

preted so as to prevent the application by a Contracting State of the anti-

avoidance provisions provided for in its domestic law;

b) It is understood that the benefits foreseen in the Convention shall not be

granted to a resident of a Contracting State which is not the beneficial

owner of the income derived from the other Contracting State;

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.

2. With reference to the Convention:

It is understood that, in the case of Georgia, the term “political or administrative subdivisions or local authorities” means “administrative-territorial units” or “local self governing authorities”.

3. With reference to Article 2, paragraph 4, of the Convention:

It is understood that, notwithstanding the provisions of paragraph 4 of Article 2

of the Convention, if Portugal introduces a tax on worldwide capital under its domestic

law, the Portuguese authorities will notify to the Georgian authorities of its bringing

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