14 September 2017
On 8 September 2017, Portugal published Notice no. 108/2017 in the Official Gazette, announcing the entry into force of the income tax treaty with the Ivory Coast on 18 August 2017. The treaty, signed 17 March 2015, is the first of its kind between the two countries.
The treaty covers Portuguese personal income tax, corporate income tax, and surtaxes on corporate income tax. It covers the following Ivory Coast taxes:
Note the definition of royalties includes technical assistance and related services not covered by Articles 14 (Independent Personal Services) and 15 (Dependent Personal Services).
The following capital gains derived by a resident of one Contracting State may be taxed by the other State:
Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.
Both countries apply the credit method for the elimination of double taxation.
Article 30 (Entitlement to Benefits) provides that the benefits of the treaty will not be granted to a resident of a Contracting State that is not the beneficial owner of the income derived from the other State. In addition, the benefits of the treaty will not apply if the principal purpose or one of the principal purposes of any person concerned with the creation or assignment of the property or right in respect of which the income is paid was to take advantage of the benefits by means of such creation or assignment.
The treaty applies from 1 January 2018.
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