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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.


At the time of the signing of the Convention between the Government of the French Republic and the Government of the Syrian Arab Republic for the avoidance of double taxation and prevention of tax evasion and fraud with respect to taxes on income, the undersigned have agreed upon the following provisions which shall form an integral part of the Convention.

(1) With respect to the letter (a) of paragraph (3) of Article 2, the tax on salaries shall be governed by the provisions of the Convention, applicable, as appropriate, to profits of enterprises or to income from independent personal services.

(2) It is understood that in the case of France, the term "immovable property" as defined in paragraph (2) of Article 6 shall include options and similar rights relating to such property if such property is situated in France.

(3) With respect to Article 7:

  • (a) where an enterprise of a Contracting State sells merchandise or exercises an activity in the other Contracting State through a permanent establishment situated therein, the profits of such permanent establishment shall not be calculated on the basis of the total amount derived by the enterprise, but only on the basis of the income that is attributable to the actual activity of the permanent establishment in terms of such sales or for such activity;
  • (b) In the case of contracts, in particular in the case of contracts pertaining to the study, supply, installation or construction of industrial, commercial, or scientific equipment or establishments or public works, where the enterprise has a permanent establishment available to it, the profits of such permanent establishment shall not be determined on the basis of the total amount of the contract, but solely on the basis of that part of the contract which is actually performed by that permanent establishment in the Contracting State where it is situated. The profits pertaining to that part of the contract which is carried out in the Contracting State where the place of effective management of the enterprise is located are only subject to tax in that State.

(4) As regards Article 20, it is understood that the provisions of this article shall not apply, in particular, to dividends and interest as defined respectively in Articles 10 and 11.

(5) The provisions of this Convention shall not prevent France from applying the provisions of Article 212 of the General Tax Code or other similar provisions which could amend or replace those in this article.

IN WITNESS WHEREOF, the undersigned, being duly authorized thereto, have signed this Protocol.

DONE at Paris, on the 17 th day of July of the year 1998, in duplicate, in French and Arabic languages, both texts being equally authentic.