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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Portugal: Source of income

For the purposes of the Elimination of double taxation Article, profits or remuneration for personal (including professional) services performed in Portugal are deemed to be income from sources in Portugal (Article 22(5)). Where a Portuguese governmental or local authority remuneration or pension is paid to a United Kingdom national who is not also a Portuguese national, such income may be taxed in both countries and is deemed to be income from sources in Portugal (Article 18(2)(a)). Royalties are deemed to arise in the country of which the payer is a resident (Article 12(5)).