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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.

PROTOCOL

At the moment of signing this Agreement between the Republic of Croatia and the Syrian Arab Republic for the avoidance of double taxation with respect to taxes on income, the undersigned have agreed that the following provisions shall form an integral part of the Agreement:

With the reference to Article 18 of this Agreement, it is understood that nothing contained in this Article shall affect the provisions of the law of a Contracting State concerning the exemption of pensions from tax.

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

DONE at Zagreb, this eighteenth day of July 2008, in two originals, in the Croatian, Arabic and English languages, all texts being equally authentic. In case of any divergence of interpretation, the English text shall prevail.

FOR THE REPUBLIC OF CROATIA:

IVAN SUKER

FINANCE MINISTER

FOR THE SYRIAN ARAB REPUBLIC:

MOHAMED EL HUSSEIN

FINANCE MINISTER