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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.


Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or local authorities thereof, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are in particular:

  • (a) in the case of the Syrian Arab Republic:
    • (i) the income tax on commercial, industrial, and noncommercial profits;
    • (ii) the income tax on salaries and wages;
    • (iii) the income tax on nonresidents;
    • (iv) the income tax on revenue from movable and immovable capital; and
    • (v) surcharges imposed as percentages of the above-mentioned taxes, including surcharges imposed by the local authorities;
  • (hereinafter referred to as "Syrian tax");
  • (b) in the case of the Republic of Bulgaria:
    • (i) the personal income tax;
    • (ii) the corporate income tax;
    • (iii) the final tax;
  • (hereinafter referred to as "Bulgarian tax").

(4) The Convention shall apply also to any identical or similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.