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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 23

Methods for Elimination of Double Taxation

(1) In China, double taxation shall be eliminated as follows:

  • (a) Where a resident of China derives income from Syria the amount of tax on that income payable in Syria in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of the credit, however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation laws and regulations of China.
  • (b) Where the income derived from Syria is a dividend paid by a company which is a resident of Syria to a company which is a resident of China and which owns not less than 10 percent of the shares of the company paying the dividend, the credit shall take into account the tax paid to Syria by the company paying the dividend in respect of its income.

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

  • (a) Where a resident of Syria derives income which, in accordance with the provisions of this Agreement, may be taxed in China, 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 China; such deduction in any 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 China.
  • (b) Where in accordance with any provision of this Agreement, income derived by a resident of Syria from China is exempt from tax in China, Syria may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.