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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.

PROTOCOL

The Government of the Islamic Republic of Iran and The Government of the Republic of Bulgaria,

Have agreed at the signing in Tehran on 9th Ordibehesht 1383 Solar Hijra corresponding to 28th April 2004 of the Agreement between the two States for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income upon the provision which shall form an integral part of the said Agreement.

Ad paragraph 4 of Article 11:

It is understood that, the provisions of paragraph 4 of Article 11, with regard to banks wholly owned by a Contracting State shall be applied after confirmation by the Governments of both Contracting States.

DONE in duplicate in Tehran on 9th Ordibehesht 1383 Solar Hijra corresponding to 28th April 2004 in the Persian, Bulgarian and English languages, all texts being equally authentic. In case of any divergence of interpretation, the English text shall prevail.

FOR THE GOVERNMENT OF THE ISLAMIC REPUBLIC OF IRAN:

FOR THE GOVERNMENT OF THE REPUBLIC OF BULGARIA: