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Cape Verde - Senegal Tax Treaty (2018, not yet in force) — Orbitax Tax Hub

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 30

Entitle to Benefits of the Convention

(1) The provisions of this Convention shall not be construed as to, in any way, prevent the application by a Contracting State of the anti-abuse provisions of its domestic law.

(2) Notwithstanding the other provisions of this Convention, a benefit shall not be granted in respect of an item of income when if it is reasonable to conclude, having regard of all relevant facts and circumstances, that granting that benefit was one of the main purposes of any arrangement or transaction which gave rise directly or indirectly to that benefit, unless it is determined that the granting of such benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Convention.