Saudi Arabia & Syria tax treaty: Effective from January 2011

Entered into force on 1 October 2010, the income tax treaty between Saudi Arabia and Syria is effective from January 2011.

The main provisions are as follows:

Permanent establishment

The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

The term "permanent establishment" also includes:

- a building site, a construction, installation or assembly project, or supervisory activities connected therewith, but only where such site, project or activities lasts for a period of more than 6 months;

- the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within a Contracting State for a period or periods aggregating more than 6 months within any 12-month period.

Dividends