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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 5

[Non-Discrimination]

(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other Contracting State in the same circumstances are or may be subjected. This provision shall also apply to nationals who are not domiciled in one or both of the Contracting States.

The term "nationals" means all individuals possessing the nationality of a Contracting State.

(2) The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other Contracting State carrying on the same activities.

(3) Except where the provisions of paragraph (1) of Article 11, paragraph (7) of Article 15, or paragraph (8) of Article 20 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a person domiciled in the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a person domiciled in the first-mentioned State.

(4) Enterprises of a Contracting State, the capital of which is wholly or partly held or controlled, directly or indirectly, by one or more persons domiciled in the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

(5) The provisions of this Article shall, notwithstanding the provisions of Article 8, apply to taxes of every kind and description.