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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.


Independent Personnel Services

(1) Income derived by a resident of a Contracting State in respect of independent personal services or other activities of an independent character shall be taxable only in that State unless the resident habitually has, in the other Contracting State, a fixed base for the exercise of his or her activities. If he has such a fixed base, the income may be taxed in the other State but only that part of the income which is attributable to such fixed base shall be taxable.

(2) The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists, and accountants.