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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 20

Government Service

(1)

  • (a) Salaries, wages and other similar remuneration, excluding pensions, paid by a Contracting state or a political or administrative subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.
  • (b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that State who:
    • (i) is a national of that State; or
    • (ii) did not become a resident of that State solely for the purpose of rendering the services.

(2)

  • (a) Notwithstanding the provisions of paragraph (1), any pension paid by, or out of funds created by, a Contracting State or a political subdivisions or a local authority thereof, to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.
  • (b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.

(3) The provisions of Articles 16, 17, 18 and 19 shall apply to salaries and other similar remuneration, and to pensions, in respect of services rendered in connection with an industrial or commercial activity carried on by a Contracting State or a political subdivision or local authority thereof.