CONVENTIONBETWEEN JAPAN AND THE PORTUGUESE REPUBLICFOR THE AVOIDANCE OF DOUBLE TAXATION
AND THE PREVENTION OF FISCAL EVASION
WITH RESPECT TO TAXES ON INCOME

Japan and the Portuguese Republic,
Desiring to conclude a Convention for the Avoidanceof Double Taxation and the Prevention of Fiscal Evasion
with respect to Taxes on Income,Have agreed as follows:
ARTICLE 1PERSONS COVEREDThis Convention shall apply to persons who areresidents of one or both of the Contracting States.
ARTICLE 2
TAXES COVERED1.
This Convention shall apply to taxes on income imposedon behalf of a Contracting State or of its political oradministrative subdivisions or local authorities,
irrespective of the manner 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 any property, taxes
on the total amounts of wages or salaries paid byenterprises, as well as taxes on capital appreciation.
3.
The existing taxes to which this Convention shallapply are:a)in the case of Portugal:(i)the personal income tax (Imposto sobre oRendimento das Pessoas Singulares – IRS);(ii)

the corporate income tax (Imposto sobre oRendimento das Pessoas Colectivas – IRC);
and

(iii)

the surtaxes on corporate income (Derramas)(hereinafter referred to as “Portuguese tax”);
and

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b)

in the case of Japan:(i)

the income tax;(ii)

the corporation tax;(iii)

the special income tax for reconstruction;(iv)

the special corporation tax forreconstruction; and(v)

the local inhabitant taxes(hereinafter referred to as “Japanese tax”).
4.
This Convention shall apply also to any identical or
substantially similar taxes that are imposed after the dateof signature of the Convention in addition to, or in placeof, the existing taxes. The competent authorities of theContracting States shall notify each other of any
significant changes that have been made in their respective
taxation laws, within a reasonable period of time after
such changes.
ARTICLE 3
GENERAL DEFINITIONS
1.
For the purposes of this Convention, unless thecontext otherwise requires:a)the term “Portugal”, when used in a geographicalsense, means all the territory of the Portuguese
Republic in accordance with the international law
and the Portuguese legislation, including its
territorial sea, as well as those maritime areas
adjacent to the outer limit of the territorialsea, comprising the seabed and subsoil thereof,
over which the Portuguese Republic exercises
sovereign rights or jurisdiction;b)

the term “Japan”, when used in a geographicalsense, means all the territory of Japan,
including its territorial sea, in which the laws
relating to Japanese tax are in force, and all
the area beyond its territorial sea, including
the seabed and subsoil thereof, over which Japan
has sovereign rights in accordance withinternational law and in which the laws relating
to Japanese tax are in force;c)the terms “a Contracting State” and “the other
Contracting State” mean Japan or Portugal, as thecontext requires;2d)the term “tax” means Japanese tax or Portuguese
tax, as the context requires;e)the term “person” includes an individual, acompany and any other body of persons;f)the term “company” means any body corporate or
any entity that is treated as a body corporate
for tax purposes;g)the term “enterprise” applies to the carrying onof any business;h)the terms “enterprise of a Contracting State” and“enterprise of the other Contracting State” mean
respectively an enterprise carried on by aresident of a Contracting State and an enterprise
carried on by a resident of the other Contracting
State;i)the term “international traffic” means any
transport by a ship or aircraft operated by anenterprise of a Contracting State, except when
the ship or aircraft is operated solely between
places in the other Contracting State;j)the term “national” means:

k)

(i)

in the case of Portugal, any individual
possessing the Portuguese nationality andany legal person, partnership or association
deriving its status as such from the laws inforce in Portugal; and(ii)

in the case of Japan, any individual
possessing the nationality of Japan, any
juridical person created or organised under
the laws of Japan and any organisation
without juridical personality treated forthe purposes of Japanese tax as a juridical
person created or organised under the lawsof Japan;the term “competent authority” means:(i)in the case of Portugal, the Minister ofFinance, the Director General of Taxation(Director-Geral dos Impostos) or theirauthorised representative; and

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(ii)

l)

in the case of Japan, the Minister ofFinance or his authorised representative;andthe term “business” includes the performance ofprofessional services and of other activities ofan independent character.

2.
As regards the application of the Convention at any
time by a Contracting State, any term not defined thereinshall, unless the context otherwise requires, have themeaning that it has at that time under the laws of thatContracting State for the purposes of the taxes to which
the Convention applies, any meaning under the applicable
tax laws of that Contracting State prevailing over ameaning given to the term under other laws of thatContracting State.
ARTICLE 4
RESIDENT1.
For the purposes of this Convention, the term
“resident of a Contracting State” means any person who,
under the laws of that Contracting State, is liable to tax
therein by reason of his domicile, residence, place ofmanagement, place of head or main office or any othercriterion of a similar nature, and also includes thatContracting State and any political or administrative
subdivision or local authority thereof. This term,
however, does not include any person who is liable to tax
in that Contracting State in respect only of income fromsources in that Contracting State.
2.
Where by reason of the provisions of paragraph 1 an
individual is a resident of both Contracting States, thenhis status shall be determined as follows:a)he shall be deemed to be a resident only of theContracting State in which he has a permanent
home available to him; if he has a permanent homeavailable to him in both Contracting States, heshall be deemed to be a resident only of theContracting State with which his personal andeconomic relations are closer (centre of vitalinterests);b)

if the Contracting State in which he has his
centre of vital interests cannot be determined,
or if he has not a permanent home available tohim in either Contracting State, he shall bedeemed to be a resident only of the Contracting
State in which he has an habitual abode;4

c)if he has an habitual abode in both Contracting
States or in neither of them, he shall be deemed
to be a resident only of the Contracting State ofwhich he is a national;d)

if he is a national of both Contracting States orof neither of them, the competent authorities of
the Contracting States shall settle the question
by mutual agreement.

3.
Where by reason of the provisions of paragraph 1 aperson other than an individual is a resident of bothContracting States, then the competent authorities of theContracting States shall determine by mutual agreement theContracting State of which that person shall be deemed to
be a resident for the purposes of this Convention. In theabsence of a mutual agreement by the competent authoritiesof the Contracting States, the person shall not be
considered a resident of either Contracting State forthe purposes of claiming any benefits provided by theConvention, except those provided by Articles 23 and 24.
4.
Where, pursuant to any provisions of this Convention,a Contracting State reduces the rate of tax on, or exempts
from tax, income of a resident of the other Contracting
State and under the laws in force in that other Contracting
State the resident is subjected to tax by that other
Contracting State only on that part of such income which isremitted to or received in that other Contracting State,then the reduction or exemption shall apply only to so muchof such income as is remitted to or received in that other
Contracting State.
ARTICLE 5
PERMANENT ESTABLISHMENT
1.
For the purposes of this Convention, the term
“permanent establishment” means a fixed place of businessthrough which the business of an enterprise is wholly or
partly carried on.
2.
The term “permanent establishment” includes
especially:a)a place of management;b)a branch;c)an office;d)a factory;5

e)a workshop; andf)a mine, an oil or gas well, a quarry or any otherplace of extraction of natural resources.

3.
A building site or construction or installation
project constitutes a permanent establishment only if it
lasts more than twelve months.
4.
Notwithstanding the preceding provisions of this
Article, the term “permanent establishment” shall be deemed
not to include:a)the use of facilities solely for the purpose ofstorage, display or delivery of goods ormerchandise belonging to the enterprise;b)

the maintenance of a stock of goods ormerchandise belonging to the enterprise solely
for the purpose of storage, display or delivery;c)the maintenance of a stock of goods ormerchandise belonging to the enterprise solely
for the purpose of processing by anotherenterprise;d)the maintenance of a fixed place of businesssolely for the purpose of purchasing goods ormerchandise or of collecting information, for theenterprise;e)the maintenance of a fixed place of businesssolely for the purpose of carrying on, for theenterprise, any other activity of a preparatory
or auxiliary character;f)the maintenance of a fixed place of businesssolely for any combination of activities
mentioned in subparagraphs a) to e), provided
that the overall activity of the fixed place ofbusiness resulting from this combination is of apreparatory or auxiliary character.

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5.
Notwithstanding the provisions of paragraphs 1 and 2,
where a person – other than an agent of an independent
status to whom the provisions of paragraph 6 apply – isacting on behalf of an enterprise and has, and habitually
exercises, in a Contracting State an authority to conclude
contracts in the name of the enterprise, that enterpriseshall be deemed to have a permanent establishment in thatContracting State in respect of any activities which that
person undertakes for the enterprise, unless the activities
of such person are limited to those mentioned in paragraph
4 which, if exercised through a fixed place of business,would not make this fixed place of business a permanentestablishment under the provisions of that paragraph.
6.
An enterprise shall not be deemed to have a permanentestablishment in a Contracting State merely because it
carries on business in that Contracting State through a
broker, general commission agent or any other agent of an
independent status, provided that such persons are acting
in the ordinary course of their business.
7.
The fact that a company which is a resident of aContracting State controls or is controlled by a company
which is a resident of the other Contracting State, or
which carries on business in that other Contracting State(whether through a permanent establishment or otherwise),shall not of itself constitute either company a permanentestablishment of the other.
ARTICLE 6
INCOME FROM IMMOVABLE PROPERTY
1.
Income derived by a resident of a Contracting State
from immovable property (including income from agriculture
or forestry) situated in the other Contracting State may betaxed in that other Contracting State.
2.
The term “immovable property” shall have the meaning
which it has under the laws of the Contracting State inwhich the property in question is situated. The term shallin any case include property accessory to immovable
property, livestock and equipment used in agriculture andforestry, rights to which the provisions of general law
respecting landed property apply, usufruct of immovable
property and rights to variable or fixed payments as
consideration for the working of, or the right to work,
mineral deposits, sources and other natural resources;
ships and aircraft shall not be regarded as immovable
property.

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3.
The provisions of paragraph 1 shall apply to income
derived from the direct use, letting, or use in any otherform of immovable property.
4.
The provisions of paragraphs 1 and 3 shall also apply
to the income from immovable property of an enterprise.
ARTICLE 7
BUSINESS PROFITS
1.
The profits of an enterprise of a Contracting State
shall be taxable only in that Contracting State unless theenterprise carries on business in the other Contracting
State through a permanent establishment situated therein.
If the enterprise carries on business as aforesaid, theprofits of the enterprise may be taxed in that other
Contracting State but only so much of them as is
attributable to that permanent establishment.
2.
Subject to the provisions of paragraph 3, wherean enterprise of a Contracting State carries on businessin the other Contracting State through a permanentestablishment situated therein, there shall in eachContracting State be attributed to that permanentestablishment the profits which it might be expected tomake if it were a distinct and separate enterprise engaged
in the same or similar activities under the same or similar
conditions and dealing wholly independently with theenterprise of which it is a permanent establishment.
3.
In determining the profits of a permanentestablishment, there shall be allowed as deductions
expenses which are incurred for the purposes of thepermanent establishment, including executive and generaladministrative expenses so incurred, whether in theContracting State in which the permanent establishment issituated or elsewhere.
4.
No profits shall be attributed to a permanentestablishment by reason of the mere purchase by thatpermanent establishment of goods or merchandise for theenterprise.
5.
For the purposes of the preceding paragraphs of this
Article, the profits to be attributed to the permanentestablishment shall be determined by the same method year
by year unless there is good and sufficient reason to thecontrary.

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6.
Where profits include items of income which are dealt
with separately in other Articles of this Convention, thenthe provisions of those Articles shall not be affected by
the provisions of this Article.
ARTICLE 8SHIPPING AND AIR TRANSPORT
1.
Profits from the operation of ships or aircraft ininternational traffic carried on by an enterprise of aContracting State shall be taxable only in that Contracting
State.
2.
Notwithstanding the provisions of Article 2, where an
enterprise of a Contracting State carries on the operationof ships or aircraft in international traffic, thatenterprise, if an enterprise of Portugal, shall be exempt
from the enterprise tax of Japan, and, if an enterpriseof Japan, shall be exempt from any tax similar to theenterprise tax of Japan which may hereafter be imposed in
Portugal.
3.
The provisions of the preceding paragraphs of this
Article shall also apply to profits from the participation
in a pool, a joint business or an international operating
agency.
ARTICLE 9
ASSOCIATED ENTERPRISES
1.

Where
a)

an enterprise of a Contracting State participates
directly or indirectly in the management, control
or capital of an enterprise of the other
Contracting State, orb)

the same persons participate directly or
indirectly in the management, control or capitalof an enterprise of a Contracting State and an
enterprise of the other Contracting State,

and in either case conditions are made or imposed between
the two enterprises in their commercial or financial
relations which differ from those which would be madebetween independent enterprises, then any profits which
would, but for those conditions, have accrued to one of theenterprises, but, by reason of those conditions, have notso accrued, may be included in the profits of thatenterprise and taxed accordingly.

92.
Where a Contracting State includes, in accordancewith the provisions of paragraph 1, in the profits ofan enterprise of that Contracting State – and taxes
accordingly – profits on which an enterprise of the other
Contracting State has been charged to tax in that other
Contracting State and where the competent authorities of
the Contracting States agree, upon consultation, that allor part of the profits so included are profits which would
have accrued to the enterprise of the first-mentioned
Contracting State if the conditions made between the twoenterprises had been those which would have been madebetween independent enterprises, then that other
Contracting State shall make an appropriate adjustment
to the amount of the tax charged therein on those agreed
profits. In determining such adjustment, due regard shallbe had to the other provisions of this Convention.
3.
Notwithstanding the provisions of paragraph 1, aContracting State shall not change the profits of anenterprise of that Contracting State in the circumstancesreferred to in that paragraph after seven years from theend of the taxable year in which the profits that would be
subjected to such change would, but for the conditions
referred to in that paragraph, have accrued to thatenterprise. The provisions of this paragraph shall not
apply in the case of fraud or wilful default.
ARTICLE 10
DIVIDENDS
1.
Dividends paid by a company which is a resident of aContracting State to a resident of the other Contracting
State may be taxed in that other Contracting State.
2.
However, such dividends may also be taxed in theContracting State of which the company paying the dividends
is a resident and according to the laws of that Contracting
State, but if the beneficial owner of the dividends is a
resident of the other Contracting State, the tax so charged
shall not exceed:a)5 per cent of the gross amount of the dividends
if the beneficial owner is a company (other thana partnership) that has owned directly for theperiod of twelve months ending on the date on
which entitlement to the dividends is determined,
either:(i)

at least 10 per cent of the voting shares of
the company paying the dividends where suchcompany is a resident of Japan; or

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(ii)

b)

at least 10 per cent of the capital of thecompany paying the dividends where suchcompany is a resident of Portugal; or

10 per cent of the gross amount of the dividends
in all other cases.

This paragraph shall not affect the taxation of thecompany in respect of the profits out of which thedividends are paid.
3.
The term “dividends” as used in this Article means
income from shares or other rights, not being debt-claims,
participating in profits, as well as income from othercorporate rights which is subjected to the same taxation
treatment as income from shares by the laws of theContracting State of which the company making the
distribution is a resident.
4.
The provisions of paragraphs 1 and 2 shall not apply
if the beneficial owner of the dividends, being a residentof a Contracting State, carries on business in the other
Contracting State of which the company paying the dividends
is a resident through a permanent establishment situatedtherein and the holding in respect of which the dividends
are paid is effectively connected with such permanentestablishment. In such case the provisions of Article 7
shall apply.
5.
Where a company which is a resident of a Contracting
State derives profits or income from the other Contracting
State, that other Contracting State may not impose any tax
on the dividends paid by the company, except insofar as
such dividends are paid to a resident of that other
Contracting State or insofar as the holding in respectof which the dividends are paid is effectively connectedwith a permanent establishment situated in that other
Contracting State, nor subject the company’s undistributed
profits to a tax on the company’s undistributed profits,even if the dividends paid or the undistributed profits
consist wholly or partly of profits or income arising insuch other Contracting State.
ARTICLE 11
INTEREST
1.
Interest arising in a Contracting State and paid to aresident of the other Contracting State may be taxed inthat other Contracting State.

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2.
However, such interest may also be taxed in theContracting State in which it arises and according to thelaws of that Contracting State, but if the beneficial ownerof the interest is a resident of the other Contracting
State, the tax so charged shall not exceed 10 per cent of
the gross amount of the interest.
3.
Notwithstanding the provisions of paragraph 2, the tax
charged by a Contracting State on interest arising in thatContracting State, if the interest is beneficially owned bya bank which is a resident of the other Contracting Stateand is established and regulated as such under the laws ofthat other Contracting State, shall not exceed 5 per centof the gross amount of the interest.
4.
Notwithstanding the provisions of paragraphs 2 and 3,
interest arising in a Contracting State shall be taxable
only in the other Contracting State if the interest is
beneficially owned by that other Contracting State, apolitical or administrative subdivision or local authority
thereof, or the central bank of that other Contracting
State.
5.
The term “interest” as used in this Article means
income from debt-claims of every kind, whether or notsecured by mortgage and whether or not carrying a right toparticipate in the debtor’s profits, and in particular,
income from government securities and income from bonds ordebentures, including premiums and prizes attaching to suchsecurities, bonds or debentures, and all other income thatis subjected to the same taxation treatment as income frommoney lent by the tax laws of the Contracting State inwhich the income arises. Income dealt with in Article 10
shall not be regarded as interest for the purposes of thisConvention.
6.
The provisions of paragraphs 1, 2 and 3 shall not
apply if the beneficial owner of the interest, being a
resident of a Contracting State, carries on business inthe other Contracting State in which the interest arises
through a permanent establishment situated therein and thedebt-claim in respect of which the interest is paid iseffectively connected with such permanent establishment.
In such case the provisions of Article 7 shall apply.

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7.
Interest shall be deemed to arise in a Contracting
State when the payer is a resident of that Contracting
State. Where, however, the person paying the interest,
whether he is a resident of a Contracting State or not,has in a Contracting State a permanent establishment inconnection with which the indebtedness on which theinterest is paid was incurred, and such interest is borneby such permanent establishment, then such interest shallbe deemed to arise in the Contracting State in which thepermanent establishment is situated.
8.
Where, by reason of a special relationship between thepayer and the beneficial owner or between both of them andsome other person, the amount of the interest, having
regard to the debt-claim for which it is paid, exceeds theamount which would have been agreed upon by the payer andthe beneficial owner in the absence of such relationship,
the provisions of this Article shall apply only to thelast-mentioned amount. In such case, the excess part ofthe payments shall remain taxable according to the laws ofeach Contracting State, due regard being had to the otherprovisions of this Convention.
ARTICLE 12
ROYALTIES
1.
Royalties arising in a Contracting State and paid toa resident of the other Contracting State may be taxed inthat other Contracting State.
2.
However, such royalties may also be taxed in theContracting State in which they arise and according to thelaws of that Contracting State, but if the beneficial ownerof the royalties is a resident of the other Contracting
State, the tax so charged shall not exceed 5 per cent of
the gross amount of the royalties.
3.
The term “royalties” as used in this Article means
payments of any kind received as a consideration for theuse of, or the right to use, any copyright of literary,artistic or scientific work including software,cinematograph films and films or tapes for radio or
television broadcasting, any patent, trade mark, design
or model, plan, or secret formula or process, or for
information concerning industrial, commercial or scientificexperience.

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4.
The provisions of paragraphs 1 and 2 shall not apply
if the beneficial owner of the royalties, being a residentof a Contracting State, carries on business in the other
Contracting State in which the royalties arise through apermanent establishment situated therein and the right orproperty in respect of which the royalties are paid iseffectively connected with such permanent establishment.
In such case the provisions of Article 7 shall apply.
5.
Royalties shall be deemed to arise in a Contracting
State when the payer is a resident of that Contracting
State. Where, however, the person paying the royalties,
whether he is a resident of a Contracting State or not,has in a Contracting State a permanent establishment inconnection with which the liability to pay the royalties
was incurred, and such royalties are borne by suchpermanent establishment, then such royalties shall bedeemed to arise in the Contracting State in which thepermanent establishment is situated.
6.
Where, by reason of a special relationship between thepayer and the beneficial owner or between both of them andsome other person, the amount of the royalties, having
regard to the use, right or information for which they arepaid, exceeds the amount which would have been agreed uponby the payer and the beneficial owner in the absence ofsuch relationship, the provisions of this Article shallapply only to the last-mentioned amount. In such case, theexcess part of the payments shall remain taxable according
to the laws of each Contracting State, due regard being had
to the other provisions of this Convention.
ARTICLE 13
CAPITAL GAINS
1.
Gains derived by a resident of a Contracting State
from the alienation of immovable property referred to in
Article 6 and situated in the other Contracting State may
be taxed in that other Contracting State.
2.
Gains derived by a resident of a Contracting State
from the alienation of shares or other comparable interests
in a company or of interests in a partnership or trust may
be taxed in the other Contracting State where the shares orthe interests derive at least 50 per cent of their value
directly or indirectly from immovable property referred toin Article 6 and situated in that other Contracting State.

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3.
Gains from the alienation of any property, other thanimmovable property, forming part of the business property
of a permanent establishment which an enterprise of aContracting State has in the other Contracting State,including such gains from the alienation of such apermanent establishment (alone or with the wholeenterprise), may be taxed in that other Contracting State.
4.
Gains derived by an enterprise of a Contracting State
from the alienation of ships or aircraft operated by thatenterprise in international traffic or any property, otherthan immovable property, pertaining to the operation ofsuch ships or aircraft shall be taxable only in thatContracting State.
5.
Gains from the alienation of any property other thanthat referred to in the preceding paragraphs of this
Article shall be taxable only in the Contracting State ofwhich the alienator is a resident.
ARTICLE 14
INCOME FROM EMPLOYMENT
1.
Subject to the provisions of Articles 15, 17 and 18,
salaries, wages and other similar remuneration derived by aresident of a Contracting State in respect of an employment
shall be taxable only in that Contracting State unless theemployment is exercised in the other Contracting State. If
the employment is so exercised, such remuneration as isderived therefrom may be taxed in that other Contracting
State.
2.
Notwithstanding the provisions of paragraph 1,
remuneration derived by a resident of a Contracting Statein respect of an employment exercised in the other
Contracting State shall be taxable only in the firstmentioned Contracting State if:a)the recipient is present in that other
Contracting State for a period or periods notexceeding in the aggregate 183 days in any twelve
month period commencing or ending in the taxable
year concerned; andb)

the remuneration is paid by, or on behalf of, anemployer who is not a resident of that other
Contracting State; andc)the remuneration is not borne by a permanentestablishment which the employer has in that
other Contracting State.

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3.
Notwithstanding the preceding provisions of this
Article, remuneration derived in respect of an employment
exercised aboard a ship or aircraft operated ininternational traffic by an enterprise of a Contracting
State may be taxed in that Contracting State.
ARTICLE 15
DIRECTORS’ FEES
Directors’ fees and other similar payments derived bya resident of a Contracting State in his capacity as amember of the board of directors of a company which is a
resident of the other Contracting State may be taxed inthat other Contracting State.
ARTICLE 16
ARTISTES AND SPORTSMEN
1.
Notwithstanding the provisions of Articles 7 and 14,
income derived by a resident of a Contracting State as anentertainer, such as a theatre, motion picture, radio or
television artiste, or a musician, or as a sportsman, fromhis personal activities as such exercised in the other
Contracting State, may be taxed in that other Contracting
State.
2.
Where income in respect of personal activities
exercised by an entertainer or a sportsman in his capacity
as such accrues not to the entertainer or sportsman himself
but to another person, that income may, notwithstanding theprovisions of Articles 7 and 14, be taxed in theContracting State in which the activities of theentertainer or sportsman are exercised.
ARTICLE 17
PENSIONS
Subject to the provisions of paragraph 2 of Article
18, pensions and other similar remuneration paid to aresident of a Contracting State shall be taxable only inthat Contracting State.

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ARTICLE 18
GOVERNMENT SERVICE
1.
Salaries, wages and other similar remuneration paid by
a Contracting State or a political or administrative
subdivision or local authority thereof to an individual inrespect of services rendered to that Contracting State orpolitical or administrative subdivision or local authority
shall be taxable only in that Contracting State. However,such salaries, wages and other similar remuneration shallbe taxable only in the other Contracting State if theservices are rendered in that other Contracting State andthe individual is a resident of that other Contracting
State who:a)

is a national of that other Contracting State; orb)

did not become a resident of that other
Contracting State solely for the purpose of
rendering the services.

2.
Notwithstanding the provisions of paragraph 1,
pensions and other similar remuneration paid by, or out offunds to which contributions are made or created by, aContracting State or a political or administrative
subdivision or local authority thereof to an individual inrespect of services rendered to that Contracting State orpolitical or administrative subdivision or local authority
shall be taxable only in that Contracting State. However,such pensions and other similar remuneration shall betaxable only in the other Contracting State if theindividual is a resident of, and a national of, that other
Contracting State.
3.
The provisions of Articles 14, 15, 16 and 17 shallapply 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 apolitical or administrative subdivision or local authority
thereof.

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ARTICLE 19
STUDENTS
Payments which a student or business apprentice who isor was immediately before visiting a Contracting State aresident of the other Contracting State and who is present
in the first-mentioned Contracting 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 the first-mentioned Contracting State, provided
that such payments arise from sources outside the firstmentioned Contracting State. The exemption provided bythis Article shall apply to a business apprentice only fora period not exceeding one year from the date on which hefirst begins his training in the first-mentioned
Contracting State.
ARTICLE 20
OTHER INCOME
1.
Items of income beneficially owned by a resident of aContracting State, wherever arising, not dealt with in theforegoing Articles of this Convention (hereinafter referred
to as “other income” in this Article) shall be taxable onlyin that Contracting State.
2.
The provisions of paragraph 1 shall not apply toother income, other than income from immovable property
as defined in paragraph 2 of Article 6, if the beneficial
owner of such other income, being a resident of aContracting State, carries on business in the other
Contracting State through a permanent establishment
situated therein and the right or property in respect ofwhich the other income is paid is effectively connectedwith such permanent establishment. In such case theprovisions of Article 7 shall apply.
3.
Where, by reason of a special relationship between
the resident referred to in paragraph 1 and the payer or
between both of them and some other person, the amountof other income exceeds the amount which would have been
agreed upon between them in the absence of such
relationship, the provisions of this Article shall apply
only to the last-mentioned amount. In such case, theexcess part of the payments shall remain taxable according
to the laws of each Contracting State, due regard being had
to the other provisions of this Convention.

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ARTICLE 21
LIMITATION OF RELIEF
No relief shall be available under this Convention if
it was the main purpose of any person concerned with thecreation or assignment of any right or property in respectof which the income is paid or derived to take advantage of
the Convention by means of that creation or assignment.
ARTICLE 22
ELIMINATION OF DOUBLE TAXATION
1.
In Portugal, double taxation shall be eliminated asfollows:a)

Where a resident of Portugal derives income
which, in accordance with the provisions of thisConvention, may be taxed in Japan, Portugal shallallow as a deduction from the Portuguese tax on
the income of that resident an amount equal to
the Japanese tax paid in Japan. Such deduction
shall not, however, exceed that part of thePortuguese tax as computed before the deduction
is given, which is attributable to the income
which may be taxed in Japan;b)

Where in accordance with any provisions of thisConvention income derived by a resident ofPortugal is exempt from tax in Portugal, Portugal
may nevertheless, in calculating the amount of
tax on the remaining income of such resident,
take into account the exempted income;c)

Notwithstanding the provision of subparagraph a),where a company which is a resident of Portugal
receives dividends from a company which is a
resident of Japan and which is subject to and notexempt from Japanese tax, Portugal shall allow a
deduction for such dividends included in the tax
base of the company receiving the dividends,
provided that the latter company has directly
held a participation corresponding to at least 10
per cent of the capital of the company paying thedividends for an uninterrupted period of one year
prior to the date on which the dividends are paidor, if held for a shorter period, it continues tohold that participation until the year-longcondition is satisfied. The provisions of thissubparagraph shall only apply if the profits outof which such dividends are paid are effectively
taxed at a rate of 10 per cent or higher.

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2.
In Japan, double taxation shall be eliminated asfollows:a)

Subject to the provisions of the laws of Japan
regarding the allowance as a credit against
Japanese tax of tax payable in any country otherthan Japan, where a resident of Japan derives
income from Portugal which may be taxed in
Portugal in accordance with the provisions of
this Convention, the amount of Portuguese tax
payable in respect of that income shall beallowed as a credit against the Japanese tax
imposed on that resident. The amount of credit,
however, shall not exceed that part of theJapanese tax which is appropriate to that income;b)

Where the income derived from Portugal is
dividends paid by a company which is a residentof Portugal to a company which is a resident ofJapan and which has owned at least 25 per centeither of the voting shares issued by the company
paying the dividends, or of the total sharesissued by that company, during the period of six
months immediately before the day when the
obligation to pay dividends is confirmed, such
dividends shall be excluded from the basis uponwhich the Japanese tax is imposed, provided thatsuch exclusion shall be subject to the provisionsof the laws of Japan regarding the exclusion ofdividends from the basis upon which the Japanese
tax is imposed;c)

For the purposes of the preceding subparagraphsof this paragraph, income beneficially owned by aresident of Japan which may be taxed in Portugalin accordance with the provisions of thisConvention shall be deemed to arise from sourcesin Portugal.
ARTICLE 23
NON-DISCRIMINATION

1.
Nationals of a Contracting State shall not be
subjected in the other Contracting State to any taxation or
any requirement connected therewith, which is other or moreburdensome than the taxation and connected requirements towhich nationals of that other Contracting State in the same
circumstances, in particular with respect to residence, areor may be subjected. The provisions of this paragraphshall, notwithstanding the provisions of Article 1, also
apply to persons who are not residents of one or both of
the Contracting States.

20

2.
The taxation on a permanent establishment which anenterprise of a Contracting State has in the other
Contracting State shall not be less favourably levied inthat other Contracting State than the taxation levied onenterprises of that other Contracting State carrying on thesame activities. The provisions of this paragraph shallnot be construed as obliging a Contracting State to grant
to residents of the other Contracting State any personal
allowances, reliefs and reductions for taxation purposes on
account of civil status or family responsibilities which it
grants to its own residents.
3.
Except where the provisions of paragraph 1 of Article
9, paragraph 8 of Article 11, paragraph 6 of Article 12 orparagraph 3 of Article 20 apply, interest, royalties andother disbursements paid by an enterprise of a Contracting
State to a resident of the other Contracting State shall,for the purpose of determining the taxable profits of suchenterprise, be deductible under the same conditions as if
they had been paid to a resident of the first-mentioned
Contracting State.
4.
Enterprises of a Contracting State, the capital ofwhich is wholly or partly owned or controlled, directly
or indirectly, by one or more residents of the other
Contracting State, shall not be subjected in the firstmentioned Contracting State to any taxation or any
requirement connected therewith which is other or moreburdensome than the taxation and connected requirements towhich other similar enterprises of the first-mentioned
Contracting State are or may be subjected.
5.
The provisions of this Article shall, notwithstanding
the provisions of Article 2, apply to taxes of every kindand description imposed on behalf of a Contracting State orof its political or administrative subdivisions or local
authorities.
ARTICLE 24
MUTUAL AGREEMENT PROCEDURE
1.
Where a person considers that the actions of one orboth of the Contracting States result or will result for
him in taxation not in accordance with the provisions of
this Convention, he may, irrespective of the remedies
provided by the domestic law of those Contracting States,
present his case to the competent authority of theContracting State of which he is a resident or, if hiscase comes under paragraph 1 of Article 23, to that of theContracting State of which he is a national. The case must
be presented within three years from the first notificationof the action resulting in taxation not in accordance withthe provisions of the Convention.

21

2.
The competent authority shall endeavour, if theobjection appears to it to be justified and if it is notitself able to arrive at a satisfactory solution, toresolve the case by mutual agreement with the competentauthority of the other Contracting State, with a view tothe avoidance of taxation which is not in accordance withthe provisions of this Convention. Any agreement reachedshall be implemented notwithstanding any time limits in thedomestic law of the Contracting States.
3.
The competent authorities of the Contracting Statesshall endeavour to resolve by mutual agreement any
difficulties or doubts arising as to the interpretation
or application of this Convention. They may also consult
together for the elimination of double taxation in cases
not provided for in the Convention.
4.
The competent authorities of the Contracting States
may communicate with each other directly, including througha joint commission consisting of themselves or theirrepresentatives, for the purposes of reaching an agreementin the sense of the preceding paragraphs of this Article.
5.

Where,
a)under paragraph 1, a person has presented a caseto the competent authority of a Contracting Stateon the basis that the actions of one or both of
the Contracting States have resulted for that
person in taxation not in accordance with theprovisions of this Convention, andb)the competent authorities are unable to reach an
agreement to resolve that case pursuant toparagraph 2 within two years from thepresentation of the case to the competentauthority of the other Contracting State,

any unresolved issues arising from the case shall be
submitted to arbitration if the person so requests. These
unresolved issues shall not, however, be submitted toarbitration if a decision on these issues has already been
rendered by a court or administrative tribunal of either
Contracting State. Unless a person directly affected by
the case does not accept the mutual agreement that
implements the arbitration decision, that decision shall bebinding on both Contracting States and shall be implemented
notwithstanding any time limits in the domestic laws ofthese Contracting States. The competent authorities of theContracting States shall by mutual agreement settle themode of application of this paragraph.

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ARTICLE 25
EXCHANGE OF INFORMATION
1.
The competent authorities of the Contracting Statesshall exchange such information as is foreseeably relevant
for carrying out the provisions of this Convention or to
the administration or enforcement of the domestic laws
concerning taxes of every kind and description imposed onbehalf of the Contracting States, or of their political oradministrative subdivisions or local authorities, insofar
as the taxation thereunder is not contrary to theConvention. The exchange of information is not restricted
by Articles 1 and 2.
2.
Any information received under paragraph 1 by aContracting State shall be treated as secret in the samemanner as information obtained under the domestic laws ofthat Contracting State and shall be disclosed only topersons or authorities (including courts and administrative
bodies) concerned with the assessment or collection of, theenforcement or prosecution in respect of, the determinationof appeals in relation to the taxes referred to inparagraph 1, or the oversight of the above. Such persons
or authorities shall use the information only for such
purposes. They may disclose the information in public
court proceedings or in judicial decisions.
3.
In no case shall the provisions of paragraphs 1 and 2
be construed so as to impose on a Contracting State theobligation:a)

to carry out administrative measures at variancewith the laws and administrative practice of thator of the other Contracting State;b)to supply information which is not obtainable
under the laws or in the normal course of theadministration of that or of the other
Contracting State;c)to supply information which would disclose any
trade, business, industrial, commercial or
professional secret or trade process, orinformation the disclosure of which would becontrary to public policy (ordre public).

23

4.
If information is requested by a Contracting State inaccordance with this Article, the other Contracting State
shall use its information gathering measures to obtain therequested information, even though that other Contracting
State may not need such information for its own tax
purposes. The obligation contained in the preceding
sentence is subject to the limitations of paragraph 3 but
in no case shall such limitations be construed to permit aContracting State to decline to supply information solely
because it has no domestic interest in such information.
5.
In no case shall the provisions of paragraph 3 beconstrued to permit a Contracting State to decline tosupply information solely because the information is heldby a bank, other financial institution, nominee or person
acting in an agency or a fiduciary capacity or because it
relates to ownership interests in a person.
ARTICLE 26
MEMBERS OF DIPLOMATIC MISSIONS AND
CONSULAR POSTS
Nothing in this Convention shall affect the fiscal
privileges of members of diplomatic missions or consular
posts under the general rules of international law or under
the provisions of special agreements.
ARTICLE 27
HEADINGS
The headings of the Articles of this Convention are
inserted for convenience of reference only and shall notaffect the interpretation of the Convention.
ARTICLE 28
ENTRY INTO FORCE
1.
Each of the Contracting States shall send in writing
and through diplomatic channels to the other the
notification confirming that its internal procedures
necessary for the entry into force of this Convention havebeen completed. The Convention shall enter into force on
the thirtieth day after the date of receipt of the latter
notification.
2.

The provisions of this Convention shall have effect:a)in the case of Portugal:

24

b)

(i)

with respect to taxes withheld at source,
the fact giving rise to them appearing on orafter the first day of January of thecalendar year next following that in which
the Convention enters into force; and(ii)

with respect to other taxes, as to income
arising in any taxable year beginning on orafter the first day of January of thecalendar year next following that in which
the Convention enters into force; andin the case of Japan:(i)with respect to taxes withheld at source,
for amounts taxable on or after 1 January inthe calendar year next following that inwhich the Convention enters into force;(ii)

with respect to taxes on income which are
not withheld at source, as regards income
for any taxable year beginning on or after 1
January in the calendar year next followingthat in which the Convention enters into
force; and(iii)

with respect to other taxes, as regards
taxes for any taxable year beginning on orafter 1 January in the calendar year next
following that in which the Convention
enters into force.
ARTICLE 29
TERMINATIONThis Convention shall remain in force until terminatedby a Contracting State. Either Contracting State may
terminate the Convention, through diplomatic channels, bygiving notice of termination at least six months before theend of any calendar year beginning after the expiry of five
years from the date of entry into force of the Convention.
In such event, the Convention shall cease to have effect:a)in the case of Portugal:(i)with respect to taxes withheld at source,
the fact giving rise to them appearing on orafter the first day of January of thecalendar year next following that in which
the notice is given; and

25

(ii)

b)

with respect to other taxes, as to income
arising in the taxable year beginning on orafter the first day of January of thecalendar year next following that in which
the notice is given; andin the case of Japan:(i)with respect to taxes withheld at source,
for amounts taxable on or after 1 January inthe calendar year next following that inwhich the notice is given;(ii)

with respect to taxes on income which are
not withheld at source, as regards income
for any taxable year beginning on or after 1
January in the calendar year next followingthat in which the notice is given; and(iii)

with respect to other taxes, as regards
taxes for any taxable year beginning on orafter 1 January in the calendar year next
following that in which the notice is given.

IN WITNESS WHEREOF the undersigned, being duly
authorised thereto by their respective Governments, havesigned this Convention.
DONE in duplicate at Lisbon this nineteenth day ofDecember, 2011, in the Japanese, Portuguese and English
languages, all texts being equally authentic. In case ofany divergence of interpretation of the text of thisConvention, the English text shall prevail.

FOR JAPAN:
四宮

FOR THE PORTUGUESE REPUBLIC:

信隆

Paulo Núncio

26

PROTOCOL TO THE CONVENTIONBETWEEN JAPAN AND THE PORTUGUESE REPUBLICFOR THE AVOIDANCE OF DOUBLE TAXATION
AND THE PREVENTION OF FISCAL EVASION
WITH RESPECT TO TAXES ON INCOME

At the signing of the Convention between Japan and thePortuguese Republic for the Avoidance of Double Taxationand the Prevention of Fiscal Evasion with respect to Taxes
on Income (hereinafter referred to as “the Convention”),
Japan and the Portuguese Republic have agreed upon thefollowing provisions, which shall form an integral part of
the Convention:
1.
The competent authorities of the Contracting Statesshall notify each other its internal procedures concerning
the mode of application of the Convention.
2.

For the purposes of applying the Convention:a)an item of income:(i)derived from a Contracting State through anentity that is organised in the other
Contracting State; and(ii)

treated as the income of the beneficiaries,
members or participants of that entity under
the tax laws of that other Contracting
State;

shall be eligible for the benefits of theConvention that would be granted if it weredirectly derived by a beneficiary, member orparticipant of that entity who is a resident ofthat other Contracting State, to the extent thatsuch beneficiaries, members or participants areresidents of that other Contracting State andsatisfy any other conditions specified in theConvention, without regard to whether the income
is treated as the income of such beneficiaries,
members or participants under the tax laws of thefirst-mentioned Contracting State.
b)an item of income:(i)derived from a Contracting State through anentity that is organised in the other
Contracting State; and

27

(ii)

treated as the income of that entity under
the tax laws of that other Contracting
State;

shall be eligible for the benefits of theConvention that would be granted to a resident ofthat other Contracting State, without regard towhether the income is treated as the income ofthat entity under the tax laws of the firstmentioned Contracting State, if such entity is a
resident of that other Contracting State andsatisfies any other conditions specified in theConvention.
c)an item of income:(i)derived from a Contracting State through anentity that is organised in that Contracting
State; and(ii)

treated as the income of that entity under
the tax laws of the other Contracting State;shall not be eligible for the benefits of theConvention.
3.

With reference to Article 6 of the Convention:

Income from immovable property includes income fromany property other than immovable property connected withthe use or the right to use the immovable property, orincome derived from services for the maintenance oroperation of the immovable property, either of which is
subject to the same taxation treatment as income from
immovable property by the tax laws of the Contracting Statein which the immovable property is situated.
4.
With reference to paragraph 2 of Article 8 of theConvention, if Portugal introduces any tax similar to theenterprise tax of Japan, Portugal shall send Japan throughdiplomatic channels without delay the notification
confirming the entry into force of its domestic laws
concerning that tax. In this case, the Contracting Statesshall agree on how that paragraph has effect and ceases tohave effect.

28

5.
Notwithstanding any provisions of the Convention, any
income and gains derived by a silent partner in respect ofa silent partnership (in the case of Japan, Tokumei Kumiai
and, in the case of Portugal, associação em participação)contract or other similar contract may be taxed in theContracting State in which such income and gains arise andaccording to the laws of that Contracting State.
6.
For the purposes of subparagraph a) of paragraph 2 ofArticle 10 of the Convention:
It is understood that the term “partnership” does notinclude any entity that is treated as a body corporate fortax purposes in a Contracting State and is a resident ofthat Contracting State.
7.

With reference to Article 10 of the Convention:

The provisions of subparagraph b) of paragraph 2 ofthat Article shall apply in the case of dividends paid by acompany which is entitled to a deduction for dividends paid
to its beneficiaries in computing its taxable income in theContracting State of which the company paying the dividends
is a resident.
8.
With reference to Article 11 of the Convention,
notwithstanding the provisions of paragraphs 2 and 3 ofthat Article, interest arising in Portugal and beneficiallyowned by any institution with the objective to promote
exports or development, the capital of which is wholly
owned by Japan as may be agreed upon from time to time
between the competent authorities of the Contracting Statesshall be taxable only in Japan.
9.
With reference to paragraph 3 of Article 11 of theConvention, if Portugal concludes an agreement for the
avoidance of double taxation with another state on the
exemption at source for interest beneficially owned by abank which is a resident of that other state:a)paragraph 3 of Article 11 of the Convention shallbe deleted and replaced by the following
provisions:“3.
Notwithstanding the provisions of paragraphs
1 and 2, interest arising in a Contracting Stateand beneficially owned by a bank which is a
resident of the other Contracting State and isestablished and regulated as such under the lawsof that other Contracting State shall be taxable
only in that other Contracting State.”;

29

b)

the provisions of paragraph 3 of Article 11 of
the Convention as amended by the provisions of
subparagraph a) of this paragraph shall apply:(i)in the case of Portugal:(aa) with respect to taxes withheld atsource on interest, the fact giving
rise to them appearing on or after the
first day of January of the calendar
year next following the thirtieth day
after the date of receipt of thenotification as referred to in
subparagraph c) of this paragraph; and(bb) with respect to other taxes, as tointerest arising in any taxable year
beginning on or after the first day ofJanuary of the calendar year next
following the thirtieth day after thedate of receipt of the notification as
referred to in subparagraph c) of thisparagraph; and(ii)

in the case of Japan:(aa) with respect to taxes withheld atsource on interest, for amounts
taxable on or after 1 January in thecalendar year next following thethirtieth day after the date ofreceipt of the notification as
referred to in subparagraph c) of thisparagraph; and(bb) with respect to taxes on interest
which are not withheld at source, as
regards interest for any taxable year
beginning on or after 1 January in thecalendar year next following thethirtieth day after the date ofreceipt of the notification as
referred to in subparagraph c) of thisparagraph;c)Portugal shall send Japan through diplomaticchannels without delay the notification
confirming the entry into force of such an
agreement.

30

10. Notwithstanding the provisions of paragraph 5 of
Article 13 of the Convention,
a)

Where
(i)

a Contracting State (including, for thispurpose in the case of Japan, the Deposit
Insurance Corporation of Japan) provides,
pursuant to the laws of that Contracting
State concerning failure resolution
involving imminent insolvency of financial
institutions, substantial financial
assistance to a financial institution thatis a resident of that Contracting State, and(ii)a resident of the other Contracting Stateacquires shares in the financial institution
from the first-mentioned Contracting State,

the first-mentioned Contracting State may tax
gains derived by the resident of the other
Contracting State from the alienation of suchshares, provided that the alienation is madewithin five years from the first date on whichsuch financial assistance was provided.
b)

The provisions of subparagraph a) shall not apply
if the resident of that other Contracting Stateacquired any shares in the financial institution
from the first-mentioned Contracting State before
the entry into force of the Convention or
pursuant to a binding contract entered into
before the entry into force of the Convention.

11. With reference to Article 15 of the Convention, theterm “a member of the board of directors of a company”
includes a member of the supervisory board (conselho
fiscal) or another similar organ of a company which is a
resident of Portugal, as foreseen in the corporate law(Código das Sociedades Comerciais).
12. With reference to paragraph 5 of Article 24 of theConvention:a)the provisions of paragraph 5 of Article 24 of
the Convention shall apply only to a case covered
by Article 9 of the Convention;

31

b)

notwithstanding the provisions of subparagraph a)of this paragraph, if Portugal concludes abilateral agreement for the avoidance of double
taxation with another state on the broader scopeof the provisions of arbitration after the entry
into force of the Convention, then the provisionsof paragraph 5 of Article 24 of the Convention
shall apply to a case within the same broader
scope from the thirtieth day after the date ofreceipt of the notification as referred to in
subparagraph c) of this paragraph, provided thatthe presentation as referred to in subparagraphb) of paragraph 5 of Article 24 of the Convention
is made on or after that thirtieth day;c)Portugal shall send Japan through diplomaticchannels without delay the notification
confirming the entry into force of such an
agreement.

13. With reference to paragraph 5 of Article 24 of theConvention:a)

The competent authorities shall by mutual
agreement establish a procedure in order toensure that an arbitration decision will be
implemented within two years from a request forarbitration as referred to in paragraph 5 of
Article 24 of the Convention unless actions orinaction of a person directly affected by thecase presented pursuant to that paragraph hinder
the resolution of the case or unless thecompetent authorities and that person agree
otherwise.

b)

An arbitration panel shall be established inaccordance with the following rules:(i)

An arbitration panel shall consist of threearbitrators with expertise or experience ininternational tax matters.

(ii)

Each competent authority shall appoint one
arbitrator who may be its national. The two
arbitrators appointed by the competentauthorities shall appoint the third
arbitrator who serves as the chair of thearbitration panel in accordance with theprocedures agreed by the competentauthorities.

32

(iii)All arbitrators shall not be employees of
the tax authorities of the Contracting
States, nor have had dealt with the casepresented pursuant to paragraph 1 of Article
24 of the Convention in any capacity. The
third arbitrator shall not be a national ofeither Contracting State, nor have had hisor her usual place of residence in either
Contracting State, nor have been employed byeither Contracting State.

(iv)

The competent authorities shall ensure that
all arbitrators and their staff agree, instatements sent to each competent authority,
prior to their acting in an arbitration
proceeding, to abide by and be subject tothe same confidentiality and non-disclosure
obligations described in paragraph 2 ofArticle 25 of the Convention and under theapplicable domestic laws of the Contracting
States.

(v)

Each competent authority shall bear the costof its appointed arbitrator and its own
expenses. The cost of the chair of anarbitration panel and other expenses
associated with the conduct of theproceedings shall be borne by the competentauthorities in equal shares.

c)

The competent authorities shall provide theinformation necessary for the arbitration
decision to all arbitrators and their staff
without undue delay.

d)An arbitration decision shall be treated asfollows:(i)

An arbitration decision has no formal
precedential value.

(ii)

An arbitration decision shall be final,
unless that decision is found to be
unenforceable by the courts of one of theContracting States due to a violation ofparagraph 5 of Article 24 of the Convention,of this paragraph or of any procedural rule
determined in accordance with subparagrapha) of this paragraph that may reasonably
have affected the decision. If the decision
is found to be unenforceable due to theviolation, the decision shall be considered
not to have been made.

33

e)

Where, at any time after a request forarbitration has been made and before thearbitration panel has delivered a decision to
the competent authorities and the person who
made the request for arbitration, the competentauthorities have solved all the unresolved issues
submitted to the arbitration, the case shall beconsidered as solved pursuant to paragraph 2 ofArticle 24 of the Convention and no arbitration
decision shall be provided.

14. With reference to paragraph 5 of Article 25 of theConvention, a Contracting State may decline to supply
information relating to confidential communications
between attorneys, solicitors or other admitted legal
representatives in their role as such and their clientsto the extent that the communications are protected fromdisclosure under the domestic law of that Contracting
State.
IN WITNESS WHEREOF the undersigned, being duly
authorised thereto by their respective Governments, havesigned this Protocol.
DONE in duplicate at Lisbon this nineteenth day ofDecember, 2011, in the Japanese, Portuguese and English
languages, all texts being equally authentic. In case ofany divergence of interpretation of the text of thisProtocol, the English text shall prevail.

FOR JAPAN:
四宮

FOR THE PORTUGUESE REPUBLIC:
信隆

Paulo Núncio

34