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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) The existing taxes to which the Convention shall apply are:

  • (a) In the case of Portugal:
    • (1) the property tax (contribuicao predial);
    • (2) the agricultural tax (imposto sobre a industria agricola);
    • (3) the industrial tax (contribuicao industrial);
    • (4) the tax on income from movable capital (imposto de capitais);
    • (5) the professional tax (imposto profissional);
    • (6) the complementary tax (imposto complementar);
    • (7) the tax on capital gains (imposto de maisvalias);
    • (8) the tax on income from oil (imposto sobre o rendimento do petroleo);
    • (9) any surcharges on the preceding taxes;
    • (10) other taxes charged by reference to the preceding taxes for the benefit of local authorities and the corresponding surcharges;
  • (hereinafter referred to as "Portuguese tax");
  • (b) In the case of the Federal Republic of Germany:
    • (1) the income tax (Einkommensteuer);
    • (2) the corporation tax (Korperschaftsteuer);
    • (3) the capital tax (Vermogensteuer);
    • (4) the real property tax (Grundsteuer);
    • (5) the trade tax (Gewerbesteuer);
    • (6) any surcharges on the preceding taxes;
  • (hereinafter referred to as "German tax").

(2) The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. At the beginning of each year, the competent authorities of the Contracting States shall notify each other of substantial changes which have been made in their respective taxation laws during the preceding year.