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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 2

Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of each Contracting State, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income or on elements of income including taxes on gains from the alienation of movable or immovable property as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are, in particular:

  • (a) in the case of Canada:
    • (i) the income taxes imposed by the Government of Canada under the Income Tax Act,
  • (hereinafter referred to as "Canadian tax");
  • (b) in the case of Senegal:
    • (i) the tax on companies;
    • (ii) the minimum lump-sum tax on companies;
    • (iii) the income tax on individuals;
    • (iv) the employers' lump-sum contribution;
    • (v) the capital gains tax on developed and undeveloped land;
  • (hereinafter referred to as "Senegalese tax").

(4) The Convention shall apply also to any identical or substantially similar taxes which enter into force after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.