background image
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 of 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, as well as taxes on capital appreciation.

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

  • (a) in the Republic of Finland:
    • (i) the state income taxes (valtion tuloverot; de statliga inkomstskatterna);
    • (ii) the corporate income taxes (yhteisöjen tuloverot; inkomstskatterna för samfund);
    • (iii) the communal tax (kunnallisvero; kommunalskatten);
    • (iv) the church tax (kirkollisvero; kyrkoskatten);
    • (v) the tax withheld at source from interest (korkotulon lähdevero; källskatten på ränteinkomst); and
    • (vi) the tax withheld at source from non residents' income (rajoitetusti verovelvollisen lähdevero; källskatten för begränsat skattskyldig);
  • (hereinafter referred to as "Finnish tax");
  • (b) in the Islamic Republic of Iran:
    • (i) the real estate income tax;
    • (ii) the tax on income from agriculture;
    • (iii) the tax on the profits of legal persons;
    • (iv) the tax on salary income;
    • (v) the tax on incidental income; and
    • (vi) the tax on unincorporated individual business income;
  • (hereinafter referred to as "Iranian tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes that 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 that have been made in their taxation laws.