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HMRC internal manual

International Manual

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

Limitation of relief

Article 3(2) of the Convention provides that if a Portuguese resident person is‘subject to tax’ in Portugal only in respect of the amount of any income whichis remitted to or received in Portugal and not by reference to the full amount of theincome, then the relief to be allowed by the UK is limited to the amount of the incomethat is remitted to or received in Portugal.