Debates Parlamentares - Diário 030, p. 42 (2016-11-18)

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II SÉRIE-A — NÚMERO 30 42

c) the remuneration is not borne by a permanent establishment which the employer has in the other State.

3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an

employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting

State in which the place of effective management of the enterprise is situated.

ARTICLE 15

DIRECTORS' FEES

Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a

member of the board of directors or supervisory board or of another similar organ of a company which is a resident

of the other Contracting State may be taxed in that other State.

ARTICLE 16

ARTISTES AND SPORTSMEN

1. Notwithstanding the provisions of Article 14, income derived by a resident of a Contracting State as an

entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from

his personal activities as such exercised in the other Contracting State, may be taxed in that other State.

2. Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity

as such accrues not to the entertainer or sportsman himself but to another person, that income may,

notwithstanding the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the

entertainer or sportsman are exercised.

3. Notwithstanding the provisions of paragraphs 1 and 2, income derived from activities exercised personally

and as such, by an entertainer or sportsman who is a resident of a Contracting State in the other Contracting

State shall be taxable only in the first- mentioned State if the activities exercised in the other State are mainly

financed by public funds of the first-mentioned State, by a political or administrative subdivision or a local authority

thereof, or by any of their legal persons of public law.

ARTICLE 17

PENSIONS

Subject to the provisions of paragraph 2 of Article 18, pensions and other similar remuneration paid to a

resident of a Contracting State in consideration of past employment shall be taxable only in that State.

ARTICLE 18

GOVERNMENT SERVICE

1. Salaries, wages and other similar remuneration paid 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 salaries, wages and other similar remuneration

shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is

a resident of that State who:

a) is a national of that State; or

b) did not become a resident of that State solely for the purpose of rendering the services.

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.

II SÉRIE-A — NÚMERO 30 42 c) the remuneration is not borne by a permanent establishment which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated. ARTICLE 15 DIRECTORS' FEES Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or supervisory board or of another similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. ARTICLE 16 ARTISTES AND SPORTSMEN 1. Notwithstanding the provisions of Article 14, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 2. Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised. 3. Notwithstanding the provisions of paragraphs 1 and 2, income derived from activities exercised personally and as such, by an entertainer or sportsman who is a resident of a Contracting State in the other Contracting State shall be taxable only in the first- mentioned State if the activities exercised in the other State are mainly financed by public funds of the first-mentioned State, by a political or administrative subdivision or a local authority thereof, or by any of their legal persons of public law. ARTICLE 17 PENSIONS Subject to the provisions of paragraph 2 of Article 18, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State. ARTICLE 18GOVERNMENT SERVICE 1. Salaries, wages and other similar remuneration paid 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 salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: a) is a national of that State; or b) did not become a resident of that State solely for the purpose of rendering the services. 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.

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