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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 8

Sea and Air Traffic

(1)

  • (a) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
  • (b) The profits from the operation, in international traffic, of aircraft may be taxed in accordance with the provisions of the Convention between the Government of the French Republic and the Government of the Syrian Arab Republic for the avoidance of double taxation of income from international air transport, signed on January 29, 1973.

(2) Where the place of effective management of a shipping enterprise is aboard a ship or boat, then such enterprise shall be deemed to be situated in the Contracting State in which the home harbor of this ship or boat is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship or boat is a resident.

(3) The provisions of paragraph (1) of this Article shall also apply to profits arising out of the participation in a pool, a joint business, or an international operating agency.