Once the MLI takes effect for this Convention (see the Preamble), the principal purpose test of Article 7(1) of the MLI is expected to replace Article 27(3): both States notified that provision under Article 7(17)(a) of the MLI.
This Convention shall apply to persons who are residents of one or both of the Contracting States.
Esta Convenção aplica-se às pessoas residentes de um ou de ambos os Estados Contratantes.
Single-sentence article; follows the OECD Model.
We apply tax treaties to dividends, interest, royalties, salaries and gains, prepare the relief-at-source form and refund claims, and check structures against the treaty’s anti-abuse rules. A written answer and a fixed quote within one working day.
Unofficial English translation prepared by BCA Portugal for reference. The Convention was done in Portuguese and French and only those texts are authentic. The Portuguese text is reproduced from the official publication. Editorial notes are ours and are not part of the Convention.