Portugal - Dividend

Article 10. Dividends

1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.

2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and
according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so
charged shall not exceed 10 per cent of the gross amount of the dividends.

3. The provisions of paragraph 2 shall not apply with respect to dividends paid by a company which is a resident of a Contracting
State to a company which is a resident of the other Contracting State with respect to which the provisions of the Directive on the
common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (90/435/EEC) as
it may be changed from time to time, are applicable.

4. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of paragraphs 2 and 3.

5. The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the
dividends are paid.

6. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares,
founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is
subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the
distribution is a resident.

7. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of 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 situated therein, or performs in that other State independent personal services from a fixed base situated
therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or
fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.

8. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other
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 State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent
establishment or a fixed base situated in that other 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 in
such other State.

Protocol:

XI Ad Article 10

The term "dividends" shall be understood to include any income from rights to participate in the profits of an enterprise of a
Contracting State, as far as these rights do not result from a shareholding or from dependent or independent personal services.

XII Ad Articles 10, 11 and 12

Where tax has been levied at source in excess of the amount of tax chargeable under the provisions of Articles 10, 11 and 12,
applications for the refund of the excess amount of tax have to be lodged with the competent authority of the State having levied the
tax, within a period of three years after the expiration of the calendar year in which the tax has been levied.

XIII Ad Articles 10 and 13

It is understood that income received in connection with the (partial) liquidation of a company or a purchase of own shares by a
company is treated in the Netherlands as income from shares and not as capital gains.