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ii. The payroll tax; and

iii. The property tax.

2. This Agreement shall also apply to any identical or substantially similar taxes imposed by either territory

after the date of signature of this Agreement in addition to, or in place of, any of the taxes listed in sub-paragraph

1. The competent authorities of the Parties shall notify each other of any relevant changes to the taxation and

related information gathering measures covered by this Agreement.

ARTICLE 4

DEFINITIONS

1. For the purposes of this Agreement, unless otherwise defined:

a) The term “Portugal” when used in a geographical sense comprises the territory of the Portuguese Republic

in accordance with the International Law and the Portuguese legislation;

b) The term “British Virgin Islands” means the territory of the Virgin Islands as referred to in the Virgin Islands

Constitution Order 2007;

c) “Competent authority” means:

(i) In respect of Portugal, the Minister of Finance, the Director General of Taxation (Director-Geral dos

Impostos) or their authorized representative;

(ii) In respect of the British Virgin Islands, the Financial Secretary or a person or authority designated by him

in writing;

d) “Person” includes an individual, a company and any other body of persons,

e) “National” means

i) In relation to Portugal any individual possessing the nationality or citizenship of that State; and any legal

person, partnership or association deriving its status as such from the laws in force in that State;

ii)In relation to the British Virgin Islands, any person who belongs to the British Virgin Islands by virtue of

the Virgin Islands Constitution Order 2007 (Statutory Instrument 2007 No.1678) or has a certificate of

residence of the British Virgin Islands by virtue of the Immigration and Passport Ordinance (Cap.130);

and any legal person, partnership, association or other entity deriving its status as such from the laws

in force in the British Virgin Islands.

f) “Company” means any body corporate or any entity that is treated as a body corporate for tax purposes,

g) “Publicly-traded company” means any company whose principal class of shares is listed on a recognised

stock exchange provided its listed shares can be readily purchased or sold by the public. Shares can be

purchased or sold “by the public” if the purchase or sale of shares is not implicitly or explicitly restricted to a

limited group of investors,

h) “Principal class of shares” means the class or classes of shares representing a majority of the voting power

and value of the company,

i) “Recognised stock exchange” means any stock exchange agreed upon by the competent authorities of

the Parties,

j) “Collective investment fund or scheme” means any pooled investment vehicle, irrespective of legal form.

The term “public collective investment fund or scheme” means any collective investment fund or scheme provided

the units, shares or other interests in the fund or scheme can be readily purchased, sold or redeemed by the

public. Units, shares or other interests in the fund or scheme can be readily purchased, sold or redeemed “by the

public” if the purchase, sale or redemption is not implicitly or explicitly restricted to a limited group of investors,

k) “Tax” means any tax to which the Agreement applies,

l) “Requesting Party” means the Party requesting information,

m) “Requested Party” means the Party requested to provide information,