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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 33

[Debts]

(1) Debts associated with the enterprises referred to in Articles 29 and 30 shall be charged against the property of those enterprises. If the enterprise has a permanent establishment or permanent facilities, as the case may be, in both Contracting States, the debts shall be charged against the property of the establishment or facilities with which they are associated.

(2) Debts secured by immovable property or rights in immovable property, by the ships or aircraft referred to in Article 31, by property used in the practice of a profession as provided for in Article 30, or by the property of an enterprise of the kind referred to in Article 29 shall be charged against such property. If a debt is secured by property situated in both States, it shall be charged against the property situated in each of them in proportion to the taxable value thereof.

This provision shall apply to the debts referred to in paragraph (1) only to the extent to which they are not covered in the manner provided for in that paragraph.

(3) Debts not provided for in paragraphs (1) and (2) shall be charged against the property to which the provisions of Article 32 apply.

(4) If, after the procedure provided for in the foregoing three paragraphs, there remains an outstanding balance in one of the Contracting States,such balance shall be deducted from the value of the other property liable to inheritance tax in that State. If there remains no other property subject to tax in that State or if after such deduction a balance still remains, such balance shall be charged against the property subject to tax in the other Contracting State.