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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.

ARTICLE 2

Taxes Covered

(1) This Agreement shall apply to taxes on income and on capital imposed on behalf of each Contracting State or its local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Agreement shall apply are in particular:

  • (a) in the case of the Republic of Azerbaijan:
    • (i) the tax on profits of legal persons;
    • (ii) the income tax on physical persons;
    • (iii) the tax on property;
    • (iv) the land tax;
  • (hereinafter referred to as Azerbaijan taxes);
  • (b) in the case of the Islamic Republic of Iran:
    • (i) the income tax;
    • (ii) the property tax;
  • (hereinafter referred to as the direct tax of the Islamic Republic of Iran).

(4) The Agreement shall apply also to any identical or substantially similar taxes, classified in accordance with definition of paragraph (1) of this Article, which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any changes, which have been made in their respective taxation laws.