Cabinet d'Avocats Houda";

The Additional Act to the Inter-State Cooperation Agreement on the development and exploitation of the Grand Tortue/Ahmeyim field provides in Title II for exemptions and suspensions for subcontractors involved in the GTA project. The main exemptions are set out below.

Value added tax

Article 6 of the Additional Act treats deliveries and services provided to Contractors, their subcontractors and the subcontractors of the latter as exports. Thus, these supplies and services provided within the framework of the GTA project are exempt from VAT and any turnover tax levied in the two States.
The condition laid down in the Additional Act for benefiting from this exemption is the presentation of the approval issued by the Joint Unit at the start of the intervention within the framework of the GTA project.

Import duties and taxes

Equipment, materials, machinery, vessels, installations, platforms, utility vehicles, engines, spare parts and consumables imported into Mauritania or Senegal and intended directly and exclusively for the operations of the GTA project are totally exempt from import duties and taxes. This exemption extends to fuel and lubricants used for the project’s installations and equipment. However, food products and other items intended for private use are not covered by this exemption. Subcontractors are also exempt from royalties, taxes, parafiscal charges and community levies.
In order to benefit from customs advantages, certain formalities are laid down in the Additional Act.

Exemption from income tax on securities

Profit distributions made by subcontractors of contractors and subcontractors of the latter within the framework of the GTA project are exempt from income tax on securities, both in Mauritania and Senegal, provided that the distributing company is subject to the actual profit taxation regime.
Also, in respect of transactions related to the GTA project, interest and other income generated by guarantees and current accounts paid by subcontractors of contractors and their subcontractors are also exempt from withholding tax on income from debt claims.

Exemption from taxes on financial and banking transactions

Furthermore, it should be noted that subcontractors of contractors and their subcontractors are exempt from all taxes on financial and banking transactions related to GTA project operations, including commissions, interest on credits, loans, advances and other commitments by signature.

Miscellaneous exemptions

Finally, apart from the taxes and duties provided for in the Additional Act, subcontractors and their subcontractors are exempt, in respect of petroleum operations carried out under the GTA project, from all other taxes and duties levied for the benefit of the State of Senegal, Mauritania, their subdivisions and local authorities, namely land taxes, business licence fees and the local economic contribution (CEL).