Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 3
General Definitions
(1) For the purpose of the present Convention, unless the context requires a different interpretation:
- (a) the term "Federal Republic of Germany", means the territory of application of the Fundamental law for the Republic of Germany;
- (b) the term "Iran" means the territory of the Empire of Iran;
- (c) the terms "a Contracting State" and "the other Contracting State" mean according to the context, the Federal Republic of Germany or Iran;
- (d) the term "person" means individuals, companies or any other groups of persons;
- (e) the term "enterprise" means any body corporate, or any entity which is considered, for purposes of taxation, as a body corporate;
- (f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
- (g) the term "national" means:
- (i) In the Federal Republic of Germany, all Germans in the sense of Article 116, paragraph (1), of the Fundamental Law of the Federal Republic of Germany and all legal entities, companies and associations made up by conforming to the legislation.
- (ii) In Iran, all individuals who have Iranian nationality and all companies and associations made up by conforming to the legislation in place in Iran;
- (h) the term "competent authority" means:
- (i) In the Federal Republic of Germany, the Federal Minister of Finances;
- (ii) In Iran, the Finance Minister.
(2) For the application of this Convention by a Contracting State, any term, which is not defined in this Convention, has the meaning that is attributed to it by the laws of the State concerning the taxes to which this Convention applies, unless the context requires a different interpretation.