United Kingdom / Portugal · United Kingdom–Portugal: 1968 convention (historical source)

Article 9 · Associated Enterprises

English · historical convention source

Unreviewed · applicability unverified1968 convention · historical

Where

(a) An enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or

(b) The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,

and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Citation to select or copy

United Kingdom / Portugal; HMRC, 1968 UK-Portugal Double Taxation Convention (page currently labelled not in force); edition 1968 convention · historical source; article 9; English; unreviewed source text, current applicability unverified; /editions/gb-pt-1968-hmrc-historical-html-v1/en/articles/article-9/

Disclaimers

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.

Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.

Noindex is not access control. This is a research preview, not a statement of authoritative or current law.

Source & edition

HMRC, 1968 UK-Portugal Double Taxation Convention (page currently labelled not in force)

Official online text · retained capture Official source website ↗
SHA-256 74a7ceb953e922e0510ffbae0ae65568e4af1f3ce146a5db2e0f45526d006d81
Digest scope: retained online-source capture; no PDF binary verification

Edition-specific publisher status

HMRC labels the 1968 convention “not in force” and lists the 2025 convention separately as in force. HMRC reports historical entry of the 1968 convention on 17 January 1969; that is not a replacement/end date. Article 28(4) of the separately retained 2025 source ties cessation of the prior convention’s effects to new-convention effects for the relevant tax. Do not invent one universal cessation date or treat the stale “in-force” URL suffix as current status. Keep historical text available for source and period-specific research.

historical entry of 1968 convention: 1969-01-17
no universal end-of-effects date asserted; tax-specific succession under 2025 Article 28(4): No universal date asserted
HMRC update, not entry/cessation: 2026-01-08

Retained status evidence and exact quotes

HM Revenue & Customs (HMRC) · 1968 convention: current HMRC label, with historical entry date separately stated
### 1968 UK-Portugal Double Taxation Convention — not in force The Income Tax Convention entered into force on 17 January 1969.
Publisher source ↗ · Retained evidence body
Retrieved 2026-10-20T20:31:00.084Z · quote SHA-256 ef389f61c1b39baa185b8aa7f9abaebc9c6f50d8e4bb629b377994dde03ec20a
HM Revenue & Customs (HMRC) · HMRC page update record; not instrument signature or entry date
8 January 2026 This update confirms that the 2025 UK-Portugal Double Taxation Convention is now in force.
Publisher source ↗ · Retained evidence body
Retrieved 2026-10-20T20:31:00.084Z · quote SHA-256 b1278f5f241025001874321ff3efab10964aa0f22785e6a128f95f85ababf7b7
HM Revenue & Customs (HMRC) · 2025 UK–Portugal Convention; separate entry and tax-dependent application dates
### 2025 UK-Portugal Double Taxation Convention — in force The Double Taxation Convention was signed in London on 15 September 2025. It entered into force on 29 December 2025. It is effective in the UK from: - 1 January 2026 for taxes withheld at source - 6 April 2026 for Income Tax and Capital Gains Tax - 1 April 2026 for Corporation Tax It is effective in Portugal from 1 January 2026 for taxes withheld at source and other taxes.
Publisher source ↗ · Retained evidence body
Retrieved 2026-10-20T20:31:00.084Z · quote SHA-256 243df75082be36c36e6c3058faa9c2cc4c2b5bd9b169099891c92cf4ae73de04
HM Revenue & Customs (HMRC) · 2025 Convention Article 28(4): prior 1968 treaty and 1961 transport agreement cease effects by tax; preserve historical reader, do not invent one universal termination date
- 4. The Convention between the United Kingdom of Great Britain and Northern Ireland and Portugal for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Lisbon on 27 March 1968 (“the prior Convention”) and the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Portugal for the avoidance of double taxation on income derived from sea and air transport signed at Lisbon on 31 July 1961 (“the Agreement”) shall cease to have effect in respect of any tax with effect from the date upon which this Convention has effect in respect of that tax in accordance with the provisions of paragraph 2 of this Article and the prior Convention and the Agreement shall terminate on the last such date. However, the prior Convention shall continue to have effect in respect of income arising before that date.
Publisher source ↗ · Retained evidence body
Retrieved 2026-10-20T20:31:15.061Z · quote SHA-256 058fc4e5856e64cf9ec6725850d6813d2632e1714ef1a10d4abc0da407dfb119

Publisher-reported status only. Currentness and human legal approval remain unverified.

Edition: 1968 convention · historical source
Text available here: English
Review: Unreviewed; qualified human review pending
Current applicability: Not verified
Signature: 1968-03-27
Entry into force: 1969-01-17

Languages recorded in source metadata: English. This is not a promise of available text or a translation.

Edition notes and known limitations

Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.

Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.

Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.

HMRC live page and country index mark 1968 not in force despite stale URL suffix in-force. 2025 text is retained separately.

Source authority, text completeness and currentness still require human review.

Retained metadata & integrity record

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