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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 1

Scope of Coverage

(1) This Convention shall apply to persons who are residents of one or both of the Contracting States.

(2) This Convention shall not apply to income of any kind derived from an activity carried on in Iran which is approved under the special Iranian legislation concerning contracts relating to petroleum and its derivatives.