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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Portugal: double taxation agreement, Article 8: Shipping and air transport

(1) Profits which a resident of a Contracting State derives from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.

(2) The Agreement between the Contracting States for the Avoidance of Double Taxation on Income derived from Sea and Air Transport, signed at Lisbon on 31st July,1961, shall, in relation to any tax for any period for which the present Convention has effect as respects that tax, cease to have effect so far as it exempts from United Kingdom tax or Portuguese tax, profits derived from the operation of ships or aircraft by, respectively, Portuguese undertakings or United Kingdom undertakings as therein defined.