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HMRC internal manual

Double Taxation Relief Manual

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Portugal: double taxation agreement, Article 18: Governmental functions

(1)

(a) Subject to the provisions of sub-paragraph (b) of this paragraph, remuneration or pensions paid out of public funds of the United Kingdom or Northern Ireland or of the funds of any local authority in the United Kingdom to any individual in respect of services rendered to the Government of the United Kingdom or Northern Ireland or a local authority in the United Kingdom in the discharge of functions of a governmental nature, shall be taxable only in the United Kingdom.

(b) Where the individual is a Portuguese national without also being a United Kingdom national, sub-paragraph (a) of this paragraph shall not apply, but the remuneration or pension shall, for the purposes of Article 22, be deemed to be income from a source within the United Kingdom.

(2)

(a) Subject to the provisions of sub-paragraph (b) of this paragraph, remuneration or pensions paid by, or out of funds created by, Portugal or a local authority thereof to any individual in respect of services rendered to Portugal or a local authority thereof, in the discharge of functions of a governmental nature, shall be taxable only in Portugal.

(b) Where the individual is a national of the United Kingdom without also being a Portuguese national, sub-paragraph (a) of this paragraph shall not apply, but the remuneration or pension shall, for the purposes of Article 22, be deemed to be income from a source within Portugal.

(3) The provisions of paragraphs (1) and (2) shall not apply to remuneration or pensions in respect of services rendered in connection with any trade or business.