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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.

ARTICLE 22

Elimination of Double Taxation

(1) In the case of Canada, double taxation shall be avoided as follows:

  • (a) subject to the existing provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada and to any subsequent modification of those provisions-which shall not affect the general principle hereof-and unless a greater deduction or relief is provided under the laws of Canada, tax payable in Senegal on profits, income or gains arising in Senegal shall be deducted from any Canadian tax payable in respect of such profits, income or gains;
  • (b) where in accordance with any provision of the Convention income derived by a resident of Canada is exempt from tax in Canada, Canada may nevertheless, in calculating the amount of tax on other income take into account the exempted income.

(2) In the case of Senegal, double taxation shall be avoided as follows:

  • (a) where a resident of Senegal derives income which, in accordance with the provisions of this Convention, may be taxed in Canada, Senegal shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Canada; such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Canada;
  • (b) where, in accordance with any provision of the Convention, income derived by a resident of Senegal is exempt from tax in Senegal, Senegal may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

(3) For the purposes of this Article, profits, income or gains of a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.