Direct Tax Avoidance Agreements

Syrian Arab republic

Article 19

GOVERNMENT SERVICE

1. a) Salaries, wages and other similar remuneration other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State, or subdivision or local authority shall be taxable only in that State.

b) However such salaries wages and other similar remuneration shah be taxable only in the other Contracting State the services are rendered in that State and the individual is a resident of that State who:

(i) is a national of that State; or

(ii) did not become a resident of that Stats solely for the purpose of rendering the services.        

2. a) Any pension paid by, or out of funds created by a Contracting State or a political sub-division or a local authority thereof to an  individual in respect of services rendered to that State or sub-division or authority shall be taxable only in that State,

b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.

3. The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages and other similar remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.

4. Nothing contained in paragraph 2 shall affect the provisions of the law of a Contracting State concerning the exemption of pensions from tax.