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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.


Taxes Covered

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

(2) There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, 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:

  • (a) in the case of the Islamic Republic of Iran:
    • (i) the income tax on real estates;
    • (ii) the income tax on agriculture;
    • (iii) the income tax on salary;
    • (iv) the income tax on business;
    • (v) the income tax on legal persons;
    • (vi) the income tax on incidental income;
  • (hereinafter referred to as "Iranian tax")
  • (b) in the case of the Republic of Bulgaria:
    • (i) the personal income tax;
    • (ii) the corporate income tax;
    • (iii) the final tax;
  • (hereinafter referred to as "Bulgarian tax").

(4) The Agreement shall apply also to any substantially similar taxes, 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 significant changes, which have been made in their respective taxation laws.