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HMRC internal manual

Double Taxation Relief Manual

Senegal: Notes

Article 5 – taxation of services

The performance of services in Senegal will result in a permanent establishment in Senegal in the following circumstances:

  • For services performed by an enterprise through employees or other personnel engaged for such purpose, where the activities continue in Senegal for a period or periods aggregating more than 183 days within any 12 month period commencing or ending in the fiscal year concerned; and
  • For services performed by an individual, where that individual’s stay in Senegal is for a period or periods exceeding 183 days within any 12 month period commencing or ending in the fiscal year concerned.

Article 13 – capital gains – shares in unlisted companies

Gains, derived by a UK resident from the alienation of shares of a company which is a resident of Senegal, may be taxed in Senegal if the alienator, at any time during the 12- month period preceding such alienation, held directly or indirectly at least 50 per cent of the capital of that company. The tax in Senegal shall be charged on not more than 25 per cent of the gain.