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HMRC internal manual

International Manual

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

Other income paid to a resident of Portugal

Article 20 of the Convention

There is a subject to tax condition for other income. Full relief on distributions from UK discretionary trusts and UK estates is available under the article, provided the claimant is subject to tax.

If the recipient of the income is not subject to tax in Portugal in respect of the income, no relief is available. See INTM162090 for an explanation of ‘subject to tax’.

NIRPs and Incapacity Benefit fall under the provisions of this article - see INTM359810.