This master’s thesis proposes the challenge of exploring the Convention between the Portuguese Republic and the Republic of Angola to Eliminate Double Taxation in Matters of Income Taxes and Prevent Fraud and Tax Evasion.
It is an instrument longed for by the parties involved, especially Portugal, a country with extensive experience in concluding such agreements. Despite the Portuguese experience, this Convention presents traces of originality that, on the one hand, arouse curiosity and invite its study, and on the other hand causes some concern to the legal community in general.
Thus, we will explore this convention along the next lines, analyzing where it is diverted from the models that served as the basis for its elaboration, whether OECD Model Tax Convention and United Nations Model Tax Convention, to adopt sui generis solutions.
Keywords: Convention, Double Taxation, Income, CMOCDE, CMONU