Debates Parlamentares - Diário 030, p. 43 (2016-11-18)

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18 DE NOVEMBRO DE 2016 43

3. The provisions of Articles 14, 15, 16, and 17 shall apply to salaries, wages, pensions, and other similar

remuneration in respect of services rendered in connection with a business carried on by a Contracting State or

a political or administrative subdivision or a local authority thereof.

ARTICLE 19

PROFESSORS AND RESEARCHERS

Subject to the provisions of Article 18 an individual who is or was a resident of a Contracting State immediately

before visiting the other Contracting State, solely for the purpose of teaching or scientific research at an university,

college, school, or other similar educational or scientific research institution which is recognized as non-profitable

by the Government of that other State, or under an official programme of cultural exchange, for a period not

exceeding two years from the date of his first arrival in that other State, shall be exempt from tax in that other

State on his remuneration for such teaching or research.

ARTICLE 20

STUDENTS

Payments which a student or business apprentice who is or was immediately before visiting a Contracting

State a resident of the other Contracting State and who is present in the first-mentioned State solely for the

purpose of his education or training receives for the purpose of his maintenance, education or training shall not

be taxed in that State, provided that such payments arise from sources outside that State.

ARTICLE 21

OTHER INCOME

1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing

Articles of this Convention shall be taxable only in that State.

2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as

defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries

on business in the other Contracting State through a permanent establishment situated therein and the right or

property in respect of which the income is paid is effectively connected with such permanent establishment. In

such case the provisions of Article 7 shall apply.

3. Where, by reason of a special relationship between the person referred to in paragraph 1 and some other

person, or between both of them and some third person, the amount of the income referred to in paragraph 1

exceeds the amount (if any) which would have been agreed upon between them in the absence of such a

relationship, the provisions of this Article shall apply only to the last mentioned amount. In such a case, the excess

part of the income shall remain taxable according to the laws of each Contracting State, due regard being had to

the other provisions of this Convention.

CHAPTER IV

METHODS FOR ELIMINATION OF DOUBLE TAXATION

ARTICLE 22

ELIMINATION OF DOUBLE TAXATION

1. Where a resident of a Contracting State derives income which, in accordance with the provisions of this

Convention, may be taxed in the other Contracting State, the first-mentioned Contracting State shall allow as a

deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other State.

Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is

given, which is attributable to the income which may be taxed in that other State.

18 DE NOVEMBRO DE 2016 43 3. The provisions of Articles 14, 15, 16, and 17 shall apply to salaries, wages, pensions, and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political or administrative subdivision or a local authority thereof. ARTICLE 19 PROFESSORS AND RESEARCHERS Subject to the provisions of Article 18 an individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State, solely for the purpose of teaching or scientific research at an university, college, school, or other similar educational or scientific research institution which is recognized as non-profitable by the Government of that other State, or under an official programme of cultural exchange, for a period not exceeding two years from the date of his first arrival in that other State, shall be exempt from tax in that other State on his remuneration for such teaching or research. ARTICLE 20 STUDENTS Payments which a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State. ARTICLE 21OTHER INCOME 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State. 2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein and the right or property in respect of which the income is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. 3. Where, by reason of a special relationship between the person referred to in paragraph 1 and some other person, or between both of them and some third person, the amount of the income referred to in paragraph 1 exceeds the amount (if any) which would have been agreed upon between them in the absence of such a relationship, the provisions of this Article shall apply only to the last mentioned amount. In such a case, the excess part of the income shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. CHAPTER IV METHODS FOR ELIMINATION OF DOUBLE TAXATION ARTICLE 22 ELIMINATION OF DOUBLE TAXATION 1. Where a resident of a Contracting State derives income which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned Contracting State shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other State. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in that other State.

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