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Tax Treaty between Mali and Monaco has Entered into Force

On 30 September 2016, it was announced in Monaco's Official Journal that the income tax treaty with Mali entered into force on 1 August 2016. The treaty, signed 13 February 2012, is the first of its kind between the two countries.

Taxes Covered

The treaty covers Monaco profits tax, and covers Malian:

  • Tax on wages and salaries;
  • Tax on business profits;
  • Corporation tax;
  • Tax on property income;
  • Tax on income from securities;
  • Tax on agricultural profits;
  • Tax on capital gains on disposals;
  • Mining royalties;
  • License tax; and
  • Special tax on revaluation of immovable property.

Service PE

The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services within a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 3 months within any 12-month period.

Withholding Tax Rates

  • Dividends - 10%
  • Interest - 6%
  • Royalties - 15%

Capital Gains

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

  • Gains from the alienation of immovable property situated in the other State; and
  • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Double Taxation Relief

Monaco applies the credit method for the elimination of double taxation, while Mali generally applies the exemption method. However, Mali applies the credit method for income referred to in Articles 9 (Associated Enterprises), 10 (Dividends), 11 (Interest), 12 (Royalties), 16 (Directors' Fees) and 17 (Artistes and Sportsmen). For income referred to in Articles 10, 11 and 12, the amount of tax levied in Monaco shall be deemed to be equal to 10% of the gross dividends paid by Monaco enterprises with mixed capital, 20% for other dividends, 10% for interest and 20% for royalties.


A protocol to the treaty, signed 30 August 2013, also entered into force on 1 August. The protocol replaces Article 25 (No Prejudicial or Restrictive Measures) and Article 27 (Exchange of Information).

Effective Date

The treaty and the protocol apply from 1 January 2017.

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