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HMRC internal manual

Double Taxation Relief Manual

Ivory Coast: Employments

Condition (a) in Article 16(2) providing for exemption for a resident of one country from the other country’s tax on remuneration from an employment exercised in the other country refers to a period `not exceeding in the aggregate 183 days, including normal interruptions in work, in any period of 12 months’. `Normal interruptions in work’ is defined in Article 16(3) as any period or periods during the 12 months in question for which the recipient is temporarily absent from the other country for purposes relating to his duties in that country including any period or periods of leave, provided that he was exercising an employment both before and after any such absence.