Prevention of Treaty Abuse – Second Peer Review Report on Treaty Shopping

Senegal

A. Progress in the implementation of the minimum standard

Senegal has 19 tax agreements in force, as reported in its response to the Peer Review questionnaire, including the multilateral Regulation 08/2008/COM adopting the rules for the avoidance of double taxation within the West African Economic and Monetary Union and the rule for assistance in tax matters (the UEMOA) concluded with seven partners. 1 Its agreement with Luxembourg complies with the minimum standard.

Senegal signed the MLI in 2017, listing 17 tax agreements.

Senegal is implementing the minimum standard through the inclusion of the preamble statement and the PPT combined with the LOB.2

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

Senegal indicated in its response to the Peer Review questionnaire that the UEMOA has not been listed under the MLI as it is a regulation of the West African Economic and Monetary Union.

B. Implementation issues

No jurisdiction has raised any concerns about their agreements with Senegal.

Senegal initiated the process to terminate its agreement with Mauritius.

Summary of the jurisdiction response – Senegal

 

	Treaty partners	Compliance with the standard	If compliant, the alternative implemented	Signature of a complying instrument	The alternative implemented through the complying instrument (if not the MLI)	Comments
1	Belgium	No	N/A	Yes	N/A
2	Benin	No	N/A	No	N/A
3	Burkina Faso	No	N/A	No	N/A
4	Canada	No	N/A	Yes	N/A
5	Chinese Taipei*	No	N/A	No	N/A
6	Cote d'Ivoire	No	N/A	No	N/A
7	France	No	N/A	Yes	N/A
8	Guinea-Bissau*	No	N/A	No	N/A
9	Italy	No	N/A	Yes	N/A
10	Lebanon*	No	N/A	Yes	N/A
11	Luxembourg	Yes	PPT alone	N/A	N/A
12	Malaysia	No	N/A	Yes	N/A
13	Mali*	No	N/A	No	N/A
14	Mauritania*	No	N/A	Yes	N/A
15	Mauritius	No	N/A	Yes	N/A
16	Morocco	No	N/A	Yes	N/A
17	Niger*	No	N/A	No	N/A
18	Norway	No	N/A	Yes	N/A
19	Portugal	No	N/A	Yes	N/A
20	Qatar	No	N/A	Yes	N/A
21	Spain	No	N/A	Yes	N/A
22	Togo*	No	N/A	No	N/A
23	Tunisia	No	N/A	Yes	N/A
24	United Arab Emirates	No	N/A	Yes	N/A
25	United Kingdom	No	N/A	Yes	N/A