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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 Agreement shall apply to taxes on income imposed on behalf of a Contracting State or its political subdivisions or local authorities, 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 this Agreement shall apply are in particular:

  • (a) in the Federal Republic of Germany:
    • (i) the income tax (Einkommensteuer);
    • (ii) the corporation tax (Körperschaftsteuer); and
    • (iii) the trade tax (Gewerbesteuer);
  • including the supplements levied thereon;
  • (hereinafter referred to as "German tax");
  • (b) in the Syrian Arab Republic:
    • (i) the income tax on commercial, industrial, and non-commercial profits;
    • (ii) the income tax on salaries and wages;
    • (iii) the income tax on non-residents;
    • (iv) the income tax on revenue of 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").

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