This Convention shall apply to persons who are residents of one or both of the Contracting States. The term "competent authority" means: i) in the case of the Kingdom of Saudi Arabia, the Ministry of Finance represented by the Minister of Finance or his authorized representative; ii).
Permanent Establishment)
Income from Immovable Property)
Business Profits)
In determining the profits of a permanent establishment of a Contracting State in the other Contracting State, expenses incurred for the purposes of doing business in that State, including executive and general administrative expenses so incurred, whether in that State or elsewhere, shall be allowed as deductions. Notwithstanding any other provision, business profits derived by an enterprise of a Contracting State from the export of goods to the other Contracting State shall not be taxed in the other Contracting State. If the export contracts involve other activities carried out in the other Contracting State, the related profits shall be taxed in the other Contracting State.
In so far as it has been customary in a Contracting State to determine the profits attributable to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph (2) shall exempt that Contracting State from determining the profits to be taxed from such allocation as may be ordinary; However, the apportionment method adopted must be such that the result is consistent with the principles contained in this article. Nothing in this Article shall affect the application of any law of a Contracting State relating to the tax imposed on insurance profits to non-residents, provided that if the relevant law in force in each Contracting State at the date of signature hereof Convention is varied (other than in minor respects so as not to affect its general character) the Contracting States shall consult each other with a view to agreeing on any amendment of this paragraph as may be necessary.
Shipping and Air Transport)
Associated Enterprises)
Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits which an enterprise of another Contracting State is liable to tax in that other State, and the profits thus included are profits which would have been attributed to the enterprise of the first-mentioned State if the conditions had been , entered into between the two enterprises, are the same as those which would have been entered into between the two independent enterprises, then that other country shall make a corresponding adjustment to the amount of tax charged therein on such profits. When determining such an adjustment, other provisions of the convention must be duly taken into account, and the competent authorities of the contracting states shall, if necessary, consult with each other.
Dividends)
The provisions of paragraph 1 do not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, by means of ' a permanent establishment situated therein, or in that other Contracting State performs independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, apply. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founder's shares or other rights that are not debt claims, participating in profits, as well as income from other corporate rights subject to the same tax treatment as income from shares by the laws of the state of which the company making the distribution is a resident.
Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State shall not impose any tax on the dividends paid by the company, except where such dividends are paid to a resident of that State other state. State or in so far as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor is the retained earnings of the company subject to a tax on retained earnings of the company, even if the dividends paid or retained earnings consist in whole or in part of profits or income arising in that other country.
Income from Debt-Claims)
However, such income from debt claims may also be taxed in the Contracting State in which it arises, if the debt claims are effectively connected with a permanent establishment of the recipient of income in that State or are connected with independent personal services performed by that State. recipient of income in such state. In other cases, if the trustee is the rightful owner of income from debt claims, the tax imposed may not exceed 7.5% of the total income. The term "income from debt claims" as used in this article means income from debt claims of any kind, whether secured by mortgage or not and whether entitled to participate in the debtor's profits, and in particular income from government securities and income from bonds or debentures, including premiums and premiums attached to such securities, bonds or debentures.
Penalties for late payment shall not be considered as income from debt claims for the purposes of this article. When, due to a special relationship between the payer and the beneficial owner or between both of them and another person, the amount of income from debt claims, taking into account the claim for the debt for which it was paid, exceeds the amount for which was agreed by the payer and the beneficial owner in the absence of such a relationship, the provisions of this article will apply only to the last mentioned amount.
Royalties)
In such event, the excess of the amount paid shall remain taxable under the laws of each Contracting State, subject to the other provisions of this Convention. However, such royalties may also be taxed in the Contracting State in which they arise, if the right or property in respect of which the royalties are paid is effectively connected with a permanent establishment of the recipient of the income in that State, or connected with independent personal services performed by the recipient of the income in that state. The competent authorities of the Contracting States shall agree on the manner of application of the provision.
Where, as a result of a special relationship between the payer and the beneficial owner or between both of them and another person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount that would have been agreed in the absence of such a relationship between the payer and the beneficial owner, the provisions of this article shall apply only to the latter amount. In such case, the excess part of the payment shall remain taxable according to the laws of each Contracting State, due account being taken of the other provisions of this Agreement.
Capital Gains)
Independent Personal Services)
Dependent Personal Services)
Directors’ Remunerations)
Artistes and Sportspersons)
Pensions)
Government Service)
Students)
Teachers and Researchers)
Other Income)
Capital)
Elimination of Double Taxation)
Mutual Agreement Procedure)
The competent authorities of both Contracting States shall endeavor to resolve, by mutual agreement, any difficulty or doubt arising in connection with the interpretation or application of this Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Convention. The competent authorities of the Contracting States may decide by mutual agreement the appropriate manner of application of this Convention and, in particular, the requirements to which residents of a Contracting State shall be subject in order to benefit, in the other State, from tax reliefs. or the exceptions provided for in this Convention.
Exchange of Information)
In no case shall the provisions of the first paragraph be interpreted in such a way as to impose an obligation on the Contracting States to: Implement administrative measures that are contrary to the laws and administrative practice of this or another Contracting State. To provide information that cannot be obtained under the laws or normal administrative procedure of this or another contracting country.
Special Provisions)
Members of Diplomatic Missions and Consular Posts)
Entry into Force and Termination)
Either Contracting State may terminate the Agreement by giving written notice of termination to the other Contracting State within twelve months before the expiry of the Agreement. Any Contracting State may, after the expiration of ten years, terminate the Agreement at any time, upon giving written notice at least twelve months before the date of its desire to terminate. If the Syrian Government - pursuant to an agreement for the avoidance of double taxation concluded with another State - agrees to apply rates lower than those referred to in the second paragraph of both Articles 11 and 12 of this Treaty, the Syrian Arab Republic apply this automatically. lower rate for residents of the Kingdom of Saudi Arabia.
Without prejudice to Article 10 of this Convention on dividends, the provisions of the Convention shall not prevent the application of Syrian law in force to dividends received by a Syrian citizen on shares held by him in the Kingdom of Saudi Arabia. This Convention shall not affect the provisions of the agreement on the exchange of exemption from taxes and fees for the activities and equipment of the Arab Air Carriers Organization, executed within the framework of the Council of Arab Economic Unity.
