The tax treaty (French) (PDF 2.97 MB) signed by Senegal and Luxembourg includes: (1) language clarifying that it is not intended to create opportunities for double non-taxation: (2) a general anti-abuse provision (“principal purpose test”); (3) specific anti-abuse provisions with respect to treaty benefits relating to dividends, interest, royalties, and other income; and (4) the possibility for the countries to apply their domestic anti-abuse provisions (to the extent that this application does not result in a tax treatment that is contrary to the tax treaty’s provisions).
The tax treaty will enter into force following completion of the applicable ratification procedures in each signatory country.
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