UK-Senegal Double Taxation Agreement 2015 Synthesized Text

HM Revenue and Customs (HMRC) published a synthesized text on April 10, 2026, regarding the 2015 Double Taxation Convention between the United Kingdom of Great Britain and Northern Ireland and the Republic of Senegal. This document integrates the original 2015 agreement with modifications introduced by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, commonly referred to as the Multilateral Instrument (MLI).

The synthesized text provides a comprehensive view of how the 2015 convention is applied following the adoption of the MLI, which was signed by both the United Kingdom and Senegal on June 7, 2017. The MLI is designed to implement measures that prevent base erosion and profit shifting, ensuring that taxes are paid where economic activities occur and value is created.

MLI Implementation and Effective Dates

The Multilateral Instrument entered into force on September 1, 2022. However, its application to the UK-Senegal tax treaty occurred in stages based on the type of tax and the jurisdiction involved.

For taxes withheld at source, the MLI modifications became effective in both the United Kingdom and Senegal on January 1, 2023.

In the United Kingdom, the MLI modifications took effect at different times for different tax types:

• For corporation tax, the modifications became effective on April 1, 2023.
• For income tax and capital gains tax, the modifications became effective on April 6, 2023.

In Senegal, the MLI modifications became effective for all other taxes for taxable periods beginning on or after January 1, 2024.

The 2015 Double Taxation Convention

The foundation of the current tax relationship is the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Senegal for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains. This convention was signed on February 26, 2015, and officially entered into force on March 30, 2016.

The original 2015 convention established different effective dates for the two nations. In the United Kingdom, the treaty became effective for corporation tax for any financial year beginning on or after April 1, 2016. For income tax and capital gains tax, it became effective for any year of assessment beginning on or after April 6, 2016.

In Senegal, the convention became effective on January 1, 2017, for both tax withheld at source on income received on or after that date and for other taxes for taxable years beginning on or after the same date.

Certain provisions of the 2015 convention were implemented immediately upon its entry into force on March 30, 2016. These included:

• Article 24, which covers the Mutual agreement procedure.
• Article 25, which governs the Exchange of information.
• Article 26, which addresses Assistance in the collection of taxes.

The publication of the synthesized text by HMRC serves to clarify the current legal standing of the treaty by merging the original 2015 text with the subsequent modifications brought about by the MLI, providing a single point of reference for tax authorities and taxpayers in both countries.