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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 Convention shall apply to taxes on income imposed on behalf of a Contracting State, one of 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 and taxes on the total amount of wages or salaries paid by enterprises.

(3) The existing taxes to which this Convention shall apply are, in particular:

  • (a) in the Arab Republic of Egypt:
    • (i) immovable property tax (including land tax, building tax and ghaffir tax);
    • (ii) tax on income from movable capital;
    • (iii) tax on commercial and industrial profits;
    • (iv) tax on profits from independent personal services and all other non-commercial professions;
    • (v) income tax;
    • (vi) corporate profit tax;
    • (vii) development duty imposed under Law No. 147 of the year 1984;
    • (viii) stamp tax imposed under Law No. 111 of the year 1980;
    • (ix) supplementary taxes imposed by the Central Government as a percentage of tax mentioned above or on other taxes;
  • (hereinafter referred to as "Egyptian taxes").
  • (b) In the Syrian Arab Republic:
    • (i) tax on profits from industrial, commercial and non-commercial (independent) professions and tax on profits from selling cars;
    • (ii) tax on salaries and wages;
    • (iii) tax on non-residents;
    • (iv) tax on income from movable capital;
    • (v) tax on income from movable and immovable property;
    • (vi) tax on agricultural products;
    • (vii) supplementary taxes or duties imposed as a percentage of tax mentioned above or imposed by other methods or in any other form or percentage.
  • (hereinafter referred to as "Syrian taxes").

(4) This Convention shall also apply to taxes of an identical or substantially similar nature that are imposed after the date of signature of this Convention in addition to, or instead of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes made in their respective tax laws.