Agreement about institutions exempted from tax on interest under Tax Convention with Portugal

December 6, 2013

Ministry of Finance

Agreement about institutions exempted from tax on interest under Tax Convention with Portugal

[Provisional translation]

1. In accordance with paragraph 8 of the Protocol to the Convention between Japan and the Portuguese Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income which was signed on December 19, 2011 and entered into force on July 28, 2013, Ministry of Finance of Japan and Ministry of Finance of the Portuguese Republic agreed that the following three institutions are institutions with the objective to promote exports or development, the capital of which is wholly owned by Japan.

   • (1) the Japan Bank for International Cooperation

   • (2) the Japan International Cooperation Agency

   • (3) the Nippon Export and Investment Insurance

2. Accordingly, interest arising in Portugal and beneficially owned by these institutions will be exempted from tax in Portugal.