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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 Convention shall apply to taxes on income imposed on behalf of each Contracting State or of its political or administrative sub-divisions or 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 enterprises, as well as taxes on capital appreciation.

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

  • (a) in the case of Syria:
    • (i) the income tax on commercial, industrial and non-commercial profits;
    • (ii) the income tax on salaries and wages;
    • (iii) the income tax on non-residents;
    • (iv) the income tax on revenue of movable and immovable capital; and
    • (v) surcharges imposed as percentages of the above-mentioned taxes, including surcharges imposed by the local authorities;
  • whether or not they are collected by withholding at source;
  • (hereinafter referred to as "Syrian tax");
  • (b) in the case of Italy:
    • (1) the personal income tax (l'imposta sul reddito delle persone fisiche);
    • (2) the corporate income tax (l'imposta sul reddito delle persone giuridiche);
    • (3) the regional tax on productive activities (l'imposta regionale sulle attività produttive);
  • whether or not they are collected by withholding at source;
  • (hereinafter referred to as "Italian 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 any significant changes which have been made in their respective taxation laws.