IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Convention.

Done at Lisbon on December 2nd , in three originals, in the Greek, Portuguese and English languages, each text being equally authentic, the English text prevailing in case of doubt.

For the Government    For the Government

of the Hellenic Republic    of the Portuguese Republic

PROTOCOL

At the moment of signing the Convention between the Hellenic Republic and the Portuguese Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following which shall be an integral part of the Convention.

Ad Article 2

The Portuguese SUBSTITUTE INHERITANCE TAX (Imposto sobre sucessoes e doagoes por aven?a) on securities is not income tax, and consequently is not covered by the scope of the Convention.

Ad Article 16

According to Greece this Article also comprises the remuneration of a partner in his capacity as a manager of limited liability company or partnership. This corresponds to the interpretation of this Article done by Portugal concerning in particular any manager of a limited liability company or a partnership.

Ad Article 23

1. The provisions of Article 23 do not preclude the application of any provision of the tax law of the Contracting States dealing with thin capitalisation problems.

2. The provisions of Article 23 shall be construed in the sense that insofar as the deducibility of the incurred disbursements is concerned, each Contracting State may apply its own procedures regarding the burden of proof.

In witness whereof, the undersigned, duly authorised thereto, have signed this Protocol.

Done in Lisbon duplicate at, December 2nd of 1999 in the Greek, Portuguese and English languages, each text being equally authentic, the English text prevailing in case of doubt.

For the Government    For the Government

of the Hellenic Republic    of the Portuguese Republic