(c) Convention between the Government of the Republic of South Africa and the Government of the Portuguese Republic for the Avoidance of Double Taxation with respect to Taxes on Income, tabled in terms of section 231(2) of the Constitution, 1996. (d) Explanatory Memorandum to the Convention between the Government of the Republic of South Africa and the Government of the Portuguese Republic for the Avoidance of Double Taxation with respect to Taxes on Income.