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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) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political or administrative subdivisions or local authorities, irrespective of the system in which they are levied.

(2) There shall be regarded as taxes on income, all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which this Convention shall apply are in particular:

  • (a) In Portugal:
    • (i) the personal income tax (IRS);
    • (ii) the corporate income tax (IRC); and
    • (iii) the local surtax on corporate income tax;
  • (hereinafter referred to as the "Portuguese tax"); and
  • (b) In Sao Tome and Principe:
    • (i) the personal income tax (IRS);
    • (ii) the corporate income tax (IRC); and
    • (iii) the stamp of knowledge of the collection concerning the IRS and CRF;
  • (hereinafter referred to as "Sao Tomean tax").

(4) The taxation of income from oil activities, whose regime is established in special law, is excluded from this Convention, with the exception of Articles 25 to 28 of this Convention.

(5) The Convention shall also apply to any identical or substantially similar taxes which enter into force after the date of signature of the Convention and in addition to or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of significant changes introduced in their respective tax laws.