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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.

PROTOCOL ANNEXED TO THE TAX CONVENTION

On signing the Tax Convention between the Government of the French Republic and the Government of the Republic of Senegal, the signatories have, in view of the specific situation existing between the two States, agreed on the following declaration, which shall form an integral part of the Convention:

When a company having its fiscal domicile in one of the Contracting States is liable in that State to a tax on the distribution of income from securities and income treated as such (earnings from shares, founders' shares and company or partnership shares; interest on bonds or on any other negotiable certificates of indebtedness) and, while not having a permanent establishment in the territory of the other state, possesses in that State immovable property which is occupied by a tenant and is liable in that State to a tax of the same nature, the income subject to the said tax shall be apportioned between the two States in order to avoid double taxation.

This apportionment shall be effected in a manner similar to that laid down in Articles 15 to 17 of the Convention, according to the amount of income derived from such immovable property.

In such cases, the provisions of Article 26, paragraphs (3)(a) and (5), shall apply.

DONE at Paris on the twenty-ninth day of March 1974.

FOR THE GOVERNMENT OF THE FRENCH REPUBLIC:

FOR THE GOVERNMENT OF THE REPUBLIC OF SENEGAL: