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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.

PROTOCOL

At the time of signing this Convention between the Kingdom of Spain and the Republic of Senegal for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed on the following provisions which shall be an integral part of this Convention:

Clause against fraud:

(1) The Contracting States declare that their domestic law and the procedure relating to abuse of norm (including the convention for elimination of double taxation), however the provisions of any agreement or Convention for avoidance of double taxation, shall be applicable to fight such abuses.

(2) It is understood that the advantages of this Convention shall not be granted to persons that are not the effective beneficiaries of the items of income that originate in the other Contracting State.

IN WITNESS WHEREOF, the undersigned, duly authorized to that effect, have signed this Protocol.

DONE in duplicate at Dakar on the 5th day of December of the year 2006, in Spanish and French, each text being equally authentic.

FOR THE KINGDOM OF SPAIN:

FOR THE REPUBLIC OF SENEGAL: