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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.


General Definitions

(1) For the purposes of this Agreement, unless the context otherwise requires:

  • (a) the term "a Contracting State" and "the other Contracting State" mean the Republic of Azerbaijan or the Islamic Republic of Iran, as the context requires;
  • (b) the term "tax" means any tax covered by Article 2 of this Agreement;
  • (c) the term "person" includes an individual, a company and any other body of persons;
  • (d) the term "company" means anybody corporate or any entity, which is treated as a body corporate for tax purposes;
  • (e) the term "registered office" means head office registered under the relevant laws of either Contracting State;
  • (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 "international traffic" means any transport by a ship, boat, aircraft, or road vehicles operated by an enterprise of a Contracting State, except when the ship, boat, aircraft or road vehicles is operated solely between places in the other Contracting State;
  • (h) the term "competent authority" means:
    • (i) in the case of the Islamic Republic of Iran, the Minister of Economic affairs and Finance or his authorized representative;
    • (ii) in the case of the Republic of Azerbaijan, Ministry of Finance and the Ministry of Taxes;
  • (i) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State.

(2) As regards the application of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which the Agreement applies.