MoF decision # 293/1 dated 20 July 2020

We hereby remind you of the requirements set in the Ministry of Finance (MoF) decision # 293/1 dated 20 July 2020 in relation with the payment by your companies of services to residents of contracting states that Lebanon has a Double Tax Treaty with such as France, Cyprus or the UAE (list of the Double Tax Treaties signed by Lebanon attached).  

According to this MoF decision and in order to benefit from the provisions of Double Tax Treaties (DTT)Lebanese taxpayers contracting with parties residing in a country which Lebanon has concluded a DTT with, should submit to the tax authorities the following documents:

1)      A tax residency certificate from the other contracting state’s tax authorities for the contracting party;

2)      Commitment letter from the other party that it does not carry-on business in Lebanon in which the revenues arise, through a permanent establishment situated therein.

3)      A separate letter which should include the other party’s name and its country of residency, as well as the nature of relationship between the Company and this other party. Also, the letter should include the tax treatment the company is undergoing with respect to the amounts paid to that foreign party. The above-mentioned documents should be attached to the letter which should be sent to the tax authorities within 1 month from the date of establishing the relationship.

In case of subsequent change to the information presented above, another letter should be sent to the tax authorities to inform them about these changes before 31 January of the next year.

The tax treatment of contractual obligations with parties residing in a country which Lebanon has concluded a DTT may defer from a country to another according to the provisions of the DTT.

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