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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Ivory Coast: double taxation agreement, Article 24: Non-discrimination

  1. The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected.

  2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.

  3. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of that first-mentioned State are or may be subjected.

  4. Nothing contained in this Article shall be construed as obliging either Contracting State to grant to individuals not resident in that State any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals so resident.

  5. Notwithstanding the provisions of this Article the period of exemption from tax on profits, under any relief referred to in paragraph (2)(a) of Article 23 or any relief of a substantially similar character under paragraph (2)(b) of that Article, from which a United Kingdom enterprise established in the Ivory Coast could benefit in the Ivory Coast, shall not under any circumstances exceed 10 years.

  6. In this Article the term `taxation` means taxes referred to in Article 2 of this Convention.