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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

PROTOCOL

At the moment of the signing the Agreement between the Government of the Slovak Republic and the Government of the Syrian Arab Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following provision which shall form an integral part of the Agreement:

If Syria in any Agreement concluded with any other EU country after the date of the signature of this Agreement would agree to a lower rate than 12 percent on the gross amount of the royalties, Syria will automatically apply this lower rate on royalties paid to residents of the Slovak Republic. It will be applicable from the date on which the Agreement between Syria and the EU country concerned enters into force.

IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol.

DONE in duplicate at Damascus, this eighteenth day of February 2009, in the Slovak, Arabic and English languages, all texts being authentic. In the case of any divergence between Slovak and Arabic texts, the English text shall prevail.

FOR THE GOVERNMENT OF THE SLOVAK REPUBLIC:

FOR THE GOVERNMENT OF THE SYRIAN ARAB REPUBLIC: