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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.

ARTICLE 22

Elimination of Double Taxation

(1) In the case of Belarus, double taxation shall be eliminated as follows:

Where a resident of Belarus derives income (profits) or owns property which, in accordance with the provisions of this Agreement, may be taxed in Syria, Belarus shall allow:

  • (a) as a deduction from the tax on the income (profits) of that resident, an amount equal to the income (profits) tax paid in Syria;
  • (b) as a deduction from the tax on the immovable property of that resident, an amount equal to the tax on property paid in Syria.

Such deduction in either case shall not, however, exceed that part of the income (profits) tax or property tax, as computed before the deduction is given, which is attributable, as the case may be, to the income (profits) or the property which may be taxed in Syria.

(2) In the case of Syria, double taxation shall be eliminated as follows:

  • Where a resident of Syria derives income which, in accordance with the provisions of this Agreement, may be taxed in Belarus, then Syria shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Belarus; such deduction in either case shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Belarus.

(3) Where in accordance with any provision of this Agreement, income derived by a resident of a Contracting State from the other Contracting State is exempt from tax in that State, the first-mentioned State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.