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HMRC internal manual

Double Taxation Relief Manual

DT: Ivory Coast: double taxation agreement, Article 2: Taxes covered

  1. This Convention shall apply to taxes on income and on capital gains imposed by a Contracting State irrespective of the manner in which they are levied

  2. There shall be regarded as taxes on income and on capital gains all taxes imposed on total income, on total capital gains, or on elements of income or of capital gains, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.

  3. The existing taxes which are the subject of this Convention are:


  1. in the United Kingdom of Great Britain and Northern Ireland:
(i) the income tax;  
(ii) the corporation tax; and  
(iii) the capital gains tax;(hereinafter referred to as \`United Kingdom tax\`);  
  1. in the Republic of the Ivory Coast:
(i) the tax on industrial and commercial profits and on agricultural profits (l'impot sur les benefices industriels et commerciaux et sur les benefices agricoles);  
(ii) the tax on non-commercial profits (l'impot sur les benefices non commerciaux);  
(iii) the tax on salaries and wages (l'impot sur les traitements et salaires);  
(iv) the tax on income from movable capital (l'impot sur le revenu des capitaux mobiliers); and  
(v) the general income tax (l'impot general sur le revenu);  
(hereinafter referred to as \`Ivory Coast tax\`).  
  1. This Convention shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.