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HMRC internal manual

Double Taxation Relief Manual

Ivory Coast: Tax spared

The agreement provides for credit to be given for `tax spared’ (see INTM161270 & 161280) in the Ivory Coast under the laws of the Ivory Coast set out in Article 23(2). Relief is however restricted to `tax spared’ in the Ivory Coast for a period of ten years in respect of any one source of income. Where credit is claimed for `tax spared’ under paragraph IIA2(c)(i) or paragraph IIA4(l) of the Annex to Law No. 59-134 of 3 September 1959, the claim should be accompanied by a certificate from the Ivory Coast authorities to the effect that the relief or exemption has been given with a view to promoting industrial, commercial, scientific or educational development in the Ivory Coast (Article 23(2)(d)).

All amounts of `tax spared’ for which credit relief is given should be reported as mentioned at INTM161290.