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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.


Taxes Covered

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

(2) There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by employers.

(3) The existing taxes to which the Agreement shall apply are:

  • (a) in the case of Indonesia:
    • (i) the income tax imposed under the Undang-undang Pajak Penghasilan 1984 (Law Number 7 of 1983 as amended);
  • (hereinafter referred to as "Indonesian tax");
  • (b) in the case of Syria:
    • - the income tax on commercial, industrial and non-commercial profits;
    • - the income tax on salaries and wages;
    • - the income tax on non-residents;
    • - the income tax on revenue from movable and immovable capital;
    • - Surcharges imposed as per centages of the above taxes or in any other form or rate;
  • (hereinafter referred to as "Syrian tax").

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