S.L. 123.59 Art. 2Arrangements to have effect. The Republic, and the as follows: This the 1. This Contracting are levied. 2. There income or on movable or by employers 3. The (a) in (b) in 4. The taxes which or in place of, States shall respective 1. For the State" mean used in a of Gozo and the territorial of Malta

It is hereby declared -

(a) that the arrangements specified in the Convention set out in the Schedule to this order have been made with the Syrian Arab Republic with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of the Syrian Arab Republic:

(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 from movable and immovable capital;

(v) surcharges imposed as percentages of the above taxes or in any other form or rate;

(b) that it is expedient that those arrangements should have effect;

(c) that the Convention has entered into force on the 16 October, 2000. SCHEDULE

CONVENTION BETWEEN THE REPUBLIC OF MALTA AND THE SYRIAN ARAB REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of the Republic of Malta and the Government of the Syrian Arab desiring to conclude a Convention for the Avoidance of Double Taxation Prevention of Fiscal Evasion with respect to Taxes on Income, have agreed

Article 1

PERSONAL SCOPE Convention shall apply to persons who are residents of one or both of Contracting States. Article 2 TAXES COVERED

Convention shall apply to taxes on income imposed on behalf of a State or its local authorities, irrespective of the manner in which they shall be regarded as taxes on income all taxes imposed on total elements of income, including taxes on gains from the alienation of immovable property, taxes on the total amounts of wages or salaries paid as well as taxes on capital appreciation.

existing taxes to which the Convention shall apply are in particular: the case of Malta: the income tax; (hereinafter referred to as "Malta tax"); the case of Syria: the income tax on commercial, industrial and non-commercial profits; the income tax on salaries and wages; the income tax on non-residents; the income tax on revenue from movable and immovable capital; surcharges imposed as percentages of the above taxes or in any other form or rate; (hereinafter referred to as "Syrian tax"). Convention shall apply also to any identical or substantially similar are imposed after the date of signature of the Convention in addition to, the existing taxes. The competent authorities of the Contracting notify each other of substantial changes which have been made in their taxation laws. Article 3 GENERAL DEFINITIONS

purposes of this Convention, unless the context otherwise requires:

(a) the terms "a Contracting State" and "the other Contracting Malta or Syria, as the context requires;

(b) the term "Malta" means the Republic of Malta and, when geographical sense, means the Island of Malta, the Island the other islands of the Maltese archipelago, including waters thereof, and any area outside the territorial waters which has been or may hereafter be designated, in accordance international law and under the law of Malta concerning shelf, as an area within which the rights of Malta with seabed and subsoil and their natural resources may be exercised;

(c) the term "Syria" means, in its geographical sense, the Syrian Arab Republic, including its territorial sea, its continental shelf, the subsoil and all other areas outside territorial sea within which, in accordance with international exercises sovereign rights for the purpose of extracting the natural, vital and mining resources and all other rights and its subsoil and the superjacent waters;

(d) the term "person" includes an individual, a company and of persons;

(e) the term "national" means:

(i) any individual possessing the citizenship of a Contracting

(ii) any legal person, partnership or association deriving such from the laws in force in a Contracting State;

(f) the term "company" means any body corporate, or any treated, for tax purposes, as a body corporate;

(g) the terms "enterprise of a Contracting State" and "enterprise Contracting State" mean respectively an enterprise carried resident of a Contracting State and an enterprise carried on of the other Contracting State;

(h) the term "international traffic" means any transport by a operated by an enterprise of a Contracting State, except or aircraft is operated solely between places in the other State;

(i) the term "competent authority" means:

(i) in the case of Malta, the Minister responsible for authorised representative;

(ii) in the case of Syria, the Minister of Finance or representative.