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 1
Persons Covered
(1) The present Convention shall apply to persons who are residents of one or both of the Contracting States.
(2) The present Convention shall not apply to income of any kind derived from an activity carried out in Iran, which is approved by the Iranian legislation relating to contracts for petroleum and of its derivatives; the same is true for capital committed for the performance of such activity.