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Article 5 � taxation of services

»Ê¹ÚÌåÓýapp 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. »Ê¹ÚÌåÓýapp tax in Senegal shall be charged on not more than 25 per cent of the gain.