The document is a Legal Notice (No. 9 of 2015) titled "The Double Taxation Relief (Seychelles) Notice, 2014," setting out the arrangements made between Kenya and Seychelles for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement was signed on March 17, 2014.Taxes Covered (Article 2)The existing taxes to which the agreement applies are:

• In Kenya: The income tax chargeable in accordance with the Income Tax Act, Cap. 470.

• In Seychelles: The business tax, the income and non-monetary benefits tax, and the petroleum income tax.

Key Withholding Tax Rates (for beneficial owner resident in the other state):

• Dividends: Shall not exceed 5 percent of the gross amounts.

• Interest: Shall not exceed 10 percent of the gross amount.

• Royalties: Shall not exceed 10 percent of the gross amount.

• Management, Professional or Technical Fees: Shall not exceed 10 percent of the gross amount.

Definition of Permanent Establishment (Article 5)A "permanent establishment" generally means a fixed place of business. Specific inclusion rules apply, such as:

• A building site or construction/installation project lasting more than 6 months.

• The furnishing of services, including consultancy, lasting more than 6 months in any twelve-month period.

Entry into Force (Article 28)The agreement enters into force on the date of receipt of the latter diplomatic note confirming the completion of the required procedures. The provisions apply to income in respect of any year of income beginning on or after the first day of January next following the entry into force date, in the case of Kenya.