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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, the meaning of the terms are as follows:

  • (a) the terms "a Contracting State" and "the other Contracting State" mean Iran or Bulgaria as the context requires;
  • (b) the term "Islamic Republic of Iran" means the territory under the sovereignty and/or jurisdiction of the Islamic Republic of
  • (c) the term "Bulgaria" means the Republic of Bulgaria and when used in a geographical sense means the territory including the territorial sea over which it exercises its State sovereignty, as well as the continental shelf and the exclusive economic zone over which it exercises sovereign rights or jurisdiction in conformity with international law;
  • (d) the term "person" means:
    • (i) an individual;
    • (ii) a company or any other body of persons;
  • (e) the term "company" means any body corporate or any entity, which is treated as a body corporate for tax purposes;
  • (f) the term "head office" means a main office registered under the relevant laws of either Contracting State;
  • (g) 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;
  • (h) the term "international traffic" means any transport by a ship, aircraft, road transport vehicle or railway operated by an enterprise of a Contracting State, except when the ship, aircraft, road transport vehicle or railway is operated solely between places situated in one of the Contracting States;
  • (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;
  • (j) 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 Bulgaria, the Minister of Finance or his authorized representative.

(2) As regards the application of this Agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has at that time under the law of that State for the purposes of the taxes to which this Agreement applies. Any meaning under the applicable tax laws of that State will prevail over the meaning given to the term under other laws of that State.