The income tax treaty between Ivory Coast and Turkey was signed on 29 February 2016. The treaty is the first of its kind between the two countries.

Taxes Covered

The treaty covers Turkish income tax and corporate tax, and covers the following Ivory Coast taxes:

• Tax on business and agricultural profits;
• Tax on non-commercial profits;
• Tax on wages, salaries, pensions and annuities;
• Tax on income from movable capital;
• Tax on income from debt;
• Tax on income from land; and
• General income tax

Service PE

The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services in a Contracting State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 183 days in a calendar year.

Withholding Tax Rates

• Dividends - 5% if the beneficial owner is a company directly holding at least 10% of the paying company's capital; otherwise 10%
• Interest - 10%
• Royalties - 10%

Capital Gains

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

• Gains from the alienation of immovable property situated in the other State;
• Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State; and
• Gains from the alienation of shares deriving more than 50% of their value directly or indirectly from immovable property situated in the other State

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Double Taxation Relief

Both countries apply the credit method for the elimination of double taxation.

Entry into Force and Effect

The treaty will enter into force once the ratification instruments are exchanged, and will apply from 1 January of the year following its entry into force.