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France - Syria Tax Treaty (as amended by 2004 exchange of notes) — Orbitax Tax Hub

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 26

Entry into Force

(1) Each Contracting State shall notify the other of the procedures required for the entry into force of this Convention. The Convention shall enter into force on the first day of the second month following the date of receipt of the last notification.

(2) The provisions of the Convention shall apply to the following:

  • (a) with respect to taxes on income, imposed by way of withholding at source, to amounts taxable from the date of entry into force of the Convention;
  • (b) with respect to taxes on income, which are not imposed by way of withholding at source, to income pertaining, as per the case, to any calendar year or fiscal year beginning after the calendar year during which the Convention entered into force;
  • (c) with respect to other taxes, to taxations whose accounting period occurs after the calendar year during which the Convention entered into force.

(3) The provisions for income taxes included in the Technical Cooperation convention signed on July 2, 1970 and in the Cultural Convention signed on September 16, 1971 between the Government of the French Republic and the Government of the Syrian Arab Republic shall cease to have effect when the relevant provisions of this Convention shall apply for the first time.