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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 and on capital imposed on behalf of a Contracting State or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital or on elements of income or of capital, 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 Agreement shall apply are in particular:

  • (a) in the case of the Syrian Arab Republic:
    • (i) the tax on income derived from commercial, industrial and non-commercial (free professions) activities and profits from vehicles;
    • (ii) the income tax on salaries and wages;
    • (iii) the income tax on non-residents;
    • (iv) the income tax on capital and immovable capital;
    • (v) surcharges imposed by the State or its local authorities now or in the future as percentages on the above-mentioned taxes;
  • (hereinafter referred to as "Syrian taxes");
  • (b) in the case of the Democratic People's Republic of Korea:
    • (i) enterprise income tax;
    • (ii) personal income tax;
    • (iii) property tax;
  • (hereinafter referred to as "DPRK tax").

(4) The Agreement shall apply also to any identical or similar taxes including surcharges 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 substantial changes which have been made in their respective taxation laws.