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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 24

Non-Discrimination

(1) Nationals of a Contracting State shall not be subjected, in the other Contracting State, to any taxation or connected obligations, which are other than or more burdensome than the taxation or connected obligations to which nationals of the other State are or may be subjected to under the same circumstances.

The term "national" means:

  • (a) any individual possessing the nationality of a Contracting State; or
  • (b) any legal person, partnership and association deriving its status as such under the laws in force in a Contracting State.

(2) Taxation levied on a permanent establishment that an enterprise of a Contracting State has in the other Contracting State shall not be less favourable in that other State than the taxation levied on enterprises of the other Contracting State carrying on the same activity in that other State.

(3) The provisions of this Article shall not be construed as:

  • (a) obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, relief or reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
  • (b) violating the provisions of paragraph (9) of Article 4, and paragraph (4) of Article 120 of Law No.157 of the year 1981 and its amendments with regard to Egypt. However, where the citizens of any other State have the right to any allowances then such allowances would be similarly granted to the citizens of Syria.

(4) Enterprises of a Contracting State whose capital is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State shall not be subjected in the first-mentioned State to any taxation or connected obligations which are other than or more burdensome than the taxation or connected obligations to which other similar enterprises of that first-mentioned State are or may be subjected.

(5) The provisions of this Article shall apply to taxes of every kind and description.