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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.


Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or one of its local authorities, irrespective of the manner in which they are levied.

(2) There shall be deemed to be as taxes on income all taxes imposed on total income or on items of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amount of wages paid by employers, as well as taxes on capital gains.

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

  • (a) in the case of France:
    • (i) the income tax (l'impôt sur le revenu);
    • (ii) the corporation tax (l'impôt sur les sociétés);
    • (iii) the tax on salaries (la taxe sur les salaires);
  • (hereinafter referred to as "French tax");
  • (b) in the case of Syria:
    • (i) the income tax on industrial, commercial and non-commercial profits (l'impôt sur les bénéfices industriels, commerciaux et non commerciaux);
    • (ii) the income tax on salaries and wages (l'impôt sur le revenu provenant des traitements et salaires);
    • (iii) the income tax on non-residents (l'impôt sur le revenu applicable aux non-résidents);
    • (iv) the income tax on revenue from movable and immovable capital (l'impôt sur les revenus du patrimoine mobilier et immobilier);
    • (v) surcharges imposed as percentages of the above-mentioned taxes (les taxes additionnelles calculées en pourcentage des impôts ci-avant mentionnés);
  • (hereinafter referred to as "Syrian tax").

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