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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.


Income from Immovable Property

(1) Income from immovable property (including income from agriculture or forestry operations) may be taxed in the Contracting State in which such property is situated, under conditions provided by the law of that State.

(2) For the purposes of the Convention, the term "immovable property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agricultural and forestry operations, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work at sites of mineral deposits, sources and other natural resources; ships, boats, and aircraft shall not be regarded as immovable property.

(3) The provisions of paragraph (1) of this Article shall apply to income derived from the direct use, letting, leasing or use in any other form of immovable property.

(4) The provisions of paragraphs (1) and (3) of this Article shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.

(5) Where the ownership or shares, stocks or other rights in a company, trust or in another similar institution grants the owner the right of enjoyment with respect to immovable property situated in a Contracting State and which is held by that company trust or another similar institution, any income derived by the owner from the direct use, letting or use in any other form of his or her right of enjoyment shall be taxable in that State, the provisions of Articles 7 and 13 notwithstanding.