Article 11 - Dividends - Syria (Old - Effective upto 31-3-2009)

Article 11 : Dividends 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State shall not be taxable in the first-mentioned Contracting State. 2. The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights assimilated to income from shares or any other income which is deemed to be a dividend or distribution of a company by the taxation laws of the Contracting State of which the company making the distribution is a resident. 3. The provisions of paragraph 1 shall not apply if the recipient 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, through a permanent establishment situated therein, or performs in that other State 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 15, as the case may be, shall apply. 4. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company to persons who are not residents of that other State, or subject the company's undistributed profits to a tax on undistributed profits even if the dividends paid or the distributed profits consist wholly or partly of profits or income arising in that other State.