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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 2

Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or one of its 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 paid by enterprises as well as taxes on capital appreciation.

(3) The existing taxes to which this Convention are:

  • (a) Insofar as Algeria is concerned:
    • (1) The tax on total income;
    • (2) The tax on corporate profits;
    • (3) The tax on professional activity;
    • (4) The flat rate payment;
    • (5) The royalty and income taxes related to activities of prospecting, exploration, exploitation and pipeline transportation of hydrocarbons;
  • (hereinafter referred to as "Algerian tax");
  • (b) Insofar as Syria is concerned:
    • (1) Tax on income from commercial and industrial profits and non-commercial profits;
    • (2) Tax on income from wages;
    • (3) The income tax for non-residents;
    • (4) Tax on income from capital and immovable property;
    • (4) Additional taxes whose base is determined by tax rates applied to taxes generated, or otherwise, or other rates;
  • (hereinafter referred to as "Syrian taxes").

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