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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.

ARTICLE 2

Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of the Contracting States, its political subdivisions and local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income, taxes imposed on total income, or on items of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amount of wages or salaries paid by enterprises.

(3) The existing taxes to which this Convention shall apply are, in particular:

  • (a) insofar as Tunisia is concerned:
    • (i) the tax on the trading license;
    • (ii) the tax on profits of non-commercial professions;
    • (iii) the tax on salaries and wages;
    • (iv) the agricultural tax;
    • (v) the tax on capital gains from immovable property;
    • (vi) the tax on income from movable securities;
    • (vii) the tax on income from loans, deposits, guarantees and current accounts (IRC);
    • (viii) the exceptional contribution for solidarity;
    • (ix) the personal contribution of the State;
  • (b) Insofar as Senegal is concerned:
    • (i) the tax on income from property;
    • (ii) the tax on business profits and profits from agricultural operations;
    • (iii) the flat rate tax on companies;
    • (iv) the tax on profits of non-commercial professions;
    • (v) the tax on income from movable securities and capital;
    • (vi) the general income tax;
    • (vii) the flat rate contribution charged to employers;
    • (viii) the minimum fiscal tax;
    • (ix) the tax representative of the minimum fiscal tax;

(4) This Convention shall also apply to any identical or substantially similar taxes that are imposed in addition to, or instead of, the existing taxes; the competent authorities of the Contracting States shall notify each other, from the time of promulgation, of changes made in their respective tax laws.