Business Tax Act, 2009
Business Tax (Double Taxation Agreement) Regulations, 2011
Statutory Instrument 91 of 2011
- Not commenced
- [This is the version of this document at 8 November 2017.]
1. CitationThese Regulations may be cited as the Business Tax (Double Taxation Agreement) Regulations, 2011.
2. Declaration and effect of AgreementIt is hereby declared that the Government of the Republic of Seychelles and the Government of the Kingdom of Lesotho have entered into an Agreement for the purpose of avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and the Agreement shall have effect in relation to the tax imposed under the Act.
Agreement between the Government of the Republic of Seychelles and the Government of the Kingdom of Lesotho for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on incomePreambleThe Government of the Kingdom of Lesotho and the Government of the Republic of Seychelles,Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,Have agreed as follows:
Article 1 – Persons coveredThis Agreement shall apply to persons who are residents of one or both of the Contracting States.
Article 2 – Taxes covered
Article 3 – General definitions
Article 4 – Resident
Article 5 – Permanent establishment
Article 6 – Income from immovable property
Article 7 – Business profits
Article 8 – Shipping and air transport
Article 9 – Associated enterprises
Article 10 – Dividends
Article 11 – Interest
Article 12 – Royalties
Article 13 – Technical fees
Article 14 – Capital gains
Article 15 – Income from employment
Article 16 – Directors' feesDirectors' fees and similar payments derived by a resident of a Contracting State in that person's capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State.
Article 17 – Entertainers and sportspersons
Article 18 – Pensions and annuities
Article 19 – Government service
Article 20 – Students and business apprenticesA student or business apprentice who is present in a Contracting State solely for the purpose of the student or business apprentice's education or training and who is, or immediately before being so present was, a resident of the other Contracting State, shall be exempt from tax in the first-mentioned State on payments received from outside that first-mentioned State for the purposes of the student or business apprentice's maintenance, education or training.
Article 21 – Professors and teachers
Article 22 – Other income
Article 23 – Elimination of double taxation
Article 24 – Non-discrimination
Article 25 – Mutual agreement procedure
Article 26 – Exchange of information
Article 27 – Assistance in recovery
Article 28 – Members of diplomatic missions and consular postsNothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.
Article 29 – Entry into force
Article 30 – Termination
ProtocolAt the time of signing the Agreement between the Government of the Kingdom of Lesotho and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, the undersigned have agreed that the provisions of Article 26 may, at the discretion of the Lesotho authorities, be replaced by the following provisions:—
History of this document
08 November 2017 this version