SolvedDT16652 | Double Taxation Relief Manual: Senegal: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Senegal is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 10% (note 1) | Article 10 |
| Dividends on direct investments | 5% | Article 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which holds directly at least 25 per cent of the capital of the company paying the dividends | |
| Property income dividends | 15% | Article 10 |
| Interest | 10% (note 2) | Article 11 |
| Royalties | 10% (note 3) | Article 12 |
| Government pensions | Taxable only in Senegal unless the individual is a resident of, and a national of, the UK | Article 18 |
| Other pensions | Taxable only in the UK | Article 17 |
| Arbitration | No | Article 24 |
Note 1: A rate of 8% applies if the beneficial owner is a pension scheme established in the UK.
Note 2: Interest paid to the UK Government, its political subdivisions and local authorities are taxable only in the UK.
Note 3: For royalties relating to industrial, commercial or scientific equipment the 10% withholding rate applies to an adjusted amount equivalent to 60% of the gross amount of the royalties.