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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 10

Dividends

(1) Dividends paid by a company that is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.

(2) However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed 15 percent of the gross amount of the dividends. The provisions of this paragraph shall not affect the taxation of the profits of the company out of which the dividends are paid.

(3) Notwithstanding the provision of paragraph (2), dividends paid by a company situated in Egypt to a resident of Syria shall be taxable under the head General Taxes in Egypt. The tax on the dividends thus paid shall be imposed on the net amount of the total dividends paid. In addition, the tax levied on the income in such cases shall not be more than 15 percent of the gross amount of the dividends paid to the same person.

(4) The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights that is subject to the same taxation treatment as income from shares under the laws of the Contracting State of which the company making the distribution is a resident.

(5) The provisions of paragraphs 2 and 3 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or provides independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply.