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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 signing of the Convention between the Government of the Republic of Armenia and the Government of the Syrian Arab Republic for the avoidance of double taxation with respect to taxes on income

The undersigned have agreed upon the following provisions which form an integral part of the Convention:

With reference to Article 24 it is agreed that the Armenians who are resident only of Syria and the Syrians who are resident only of Armenia meanwhile the time of application of this Convention shall be taxed according to the rules of taxation in place of their residency.

IN WITNESS WHEREOF, the undersigned, being duly authorized thereto, by their respective Governments, have signed this Convention.

DONE in duplicate at Yerevan, this twenty-ninth day of June 2005, in the Armenian, Arabic and English languages, the texts being authentic. In case of divergence of interpretation, the English text shall prevail.

FOR THE GOVERNMENT OF THE REPUBLIC OF ARMENIA:

TIGRAN KHACHATRYAN

DEPUTY MINISTER OF FINANCE AND ECONOMY OF THE REPUBLIC OF ARMENIA

FOR THE GOVERNMENT OF THE SYRIAN ARAB REPUBLIC:

MOUHANNAD KHEDER SAYED AHMAD

DEPUTY MINISTER OF FINANCE OF THE SYRIAN ARAB REPUBLIC