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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.



(1) Within the meaning of these Regulations, unless the context otherwise requires:

  • (a) the terms "a Member State", "another Member State" and "the other Member States" means, as the context requires, one or more States of the WAEMU;
  • (b) the term "territory of a State" means, for each Member State, its territory, including, for the coastal States, the territorial sea, the areas adjacent to the territorial waters as well as the exclusive economic zone and continental shelf over which this State exercises, in accordance with international law and its domestic law, its sovereign rights for the purposes of exploration and exploitation of natural, biological and mineral resources found in the waters of the sea, the soil and subsoil thereof;
  • (c) the term "person" includes individuals, companies and any other body of persons;
  • (d) the term "company" means any-body corporate or any entity which is treated as a body corporate for tax purposes;
  • (e) the terms "enterprise of a Member State" and "enterprise of another Member State" mean, respectively an enterprise carried on by a resident of a Member State and an enterprise carried on by a resident of another Member State;
  • (f) the term "national" means any individual possessing the nationality of a Member State and any other body corporate, partnership and association incorporated under  the laws in force in a Member State;
  • (g) the term "international traffic" means any transport carried out to one or more Member States by ship or aircraft operated by an enterprise whose place of effective management is situated in a Member State except when the ship or aircraft is operated solely between places in another Member State;
  • (h) the term "competent authority" means the Ministers in charge of Finance of the Member States or their duly authorized representatives.

(2) For the purposes of the application of this Regulation by a Member State, any term not defined therein shall have the meaning assigned to it by the law of that State concerning the taxes covered by this Regulation, unless the context requires otherwise.