Decision of the Ministry of Finance No. 942/1 dated 15/11/2019 relating to the taxation treatment of liberal professions’ income derived by Lebanese residents from activities implemented in foreign countries which have signed double taxation treaties (DTT) with Lebanon.

The Ministry of Finance (MoF) issued the Decision No. 942/1 dated 15/11/2019 (here below), published in the Official Gazette No 55 on 28/11/2019, related to the determination of the taxation treatment of liberal professions’ income derived by Lebanese residents from activities implemented in foreign countries which have signed double taxation treaties (DTT) with Lebanon. This Decision has implicitly enshrined the principle of superiority of international treaties which prevail over Lebanese applicable laws or principles to the contrary in accordance with the provisions of article 2 of the Code of Civil Procedures and article 3-2 of the Code of Tax Procedures. Indeed and in compliance with this Decision, the professional revenues derived by Lebanese residents from activity implemented in a country that have signed a DTT with Lebanon are subject to the income tax in Lebanon and should be combined in consequence with the other income and revenues generated in Lebanon and subject to the tax (whether on the basis of the actual profit, or by application of the rates of the flat-rate profit according to the rate relating to the concerned activity). The provisions of the DTT shall be taken into account in applying this Decision, to the extent that they authorize the State in whose territory such profits were generated to tax such profits in that State. The Decision will apply as for the revenues of the fiscal year 2019.

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