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5 DE MAIO DE 2016 111_______________________________________________________________________________________________________________

ARTICLE 27

Entry into Force

1. This Agreement shall enter into force thirty days after the date of receipt of the latter of the

notifications, in writing and through diplomatic channels, conveying the completion of the internal procedures

of each Contracting State required for that purpose.

2. The provisions of this Agreement shall have effect:

(a) in Viet Nam:

(i) in respect of taxes withheld at source, in relation to taxable amounts as derived on or after the first

day of January following the calendar year in which the Agreement enters into force, and in subsequent

calendar years; and

(ii) in respect of other Vietnamese taxes, in relation to income, profits, gains or capital arising on or after

the first day of January following the calendar year in which the Agreement enters into force, and in

subsequent calendar years; and

(b) in Portugal:

(i) in respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of

January of the calendar year next following that in which this Agreement enters into force;

(ii) in respect of other taxes, as to income arising in any fiscal year beginning on or after the first day of

January of the calendar year next following that in which this Agreement enters into force.

ARTICLE 28

Termination

This Agreement shall remain in force until terminated by one of the Contracting States. Either Contracting

State may terminate the Agreement, through diplomatic channels, by giving to the other Contracting State,

written notice of termination at least six months before the end of any calendar year beginning after the expiry

of five years from the date of entry into force of the Agreement.

In such event, the Agreement shall cease to have effect:

(a) in Viet Nam:

(i) in respect of taxes withheld at source, in relation to taxable amounts as derived on or after the first

day of January following the calendar year in which the notice of termination has been received, and in

subsequent calendar years; and

(ii) in respect of other Vietnamese taxes, in relation to income, profits, gains or capital arising on or after

the first day of January following the calendar year in which the notice of termination has been received, and

in subsequent calendar years; and

(b) in Portugal:

(i) in respect of taxes withheld at source, the fact giving rise to them appearing on or after the first day of

January following the calendar year in which the notice of termination has been received; and

(ii) in respect of other taxes, as to income arising in the fiscal year beginning on or after the first day of

January following the calendar year in which the notice of termination has been received.

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

DONE in duplicate at Lisbon this 3rd day of June of the year two thousand and fifteen in the Portuguese,

Vietnamese and English languages, all texts being equally authentic. In case of divergence of interpretation of

the text of this Agreement, the English text shall prevail.