Companies are considered as Senegalese residents if they have a registered fixed establishment. Nonetheless, foreign companies that are not registered locally may be deemed to have a PE in Senegal in relation to their local activity and will then be subject to tax liabilities.
Permanent establishment (PE)
The criteria for a PE were derived from the former GTC and are close to the Organisation for Economic Co-operation and Development (OECD) standards. The current GTC does not include a PE provision, but the former one should be applicable. DTTs can be applicable and can provide specific definitions. These DTTs are based on the OECD model in most cases. See the Withholding taxes section for a list of countries with which Senegal has concluded DTTs.