background image

France - Senegal Tax Treaty (as amended through 1991 protocol) — Orbitax Tax Hub

CHAPTER I - INCOME TAXES
CHAPTER II - INHERITANCE TAXES
CHAPTER III - REGISTRATION DUTIES OTHER THAN INHERITANCE TAXES; STAMP DUTIES
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 11

[Associated Enterprises]

(1) When an enterprise of one of the Contracting States, by virtue of its participation in the management or the capital of an enterprise of the Contracting State, stipulates or imposes on that enterprise, in their commercial or financial relations, conditions differing from those which would be stipulated to a third enterprise, all profits which would normally have appeared in the accounts of one of the enterprises but which have in this manner been transferred to the other enterprise may be incorporated in the taxable profits of the former.

(2) In particular, an enterprise shall be deemed to participate in the management or the capital of another enterprise when the same persons participate directly or indirectly in the management or the capital of both enterprises.