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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:

  • (a) the term "the Islamic Republic of Iran" means the territory under the sovereignty and/or jurisdiction of the Islamic Republic of Iran;
  • (b) the term "Hungary" means the territory of Hungary as defined by its laws in accordance with international law;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean Hungary or the Islamic Republic of Iran, as the context requires;
  • (d) the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (e) the term "person" includes an individual, a company and any other body of persons;
  • (f) the term "enterprise" applies to the carrying on of any business;
  • (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 or road and railway vehicle operated by an enterprise of a Contracting State, except when the ship, aircraft or road and railway vehicle is operated solely between places in the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in case of the Islamic Republic of Iran, the Minister of Economic Affairs and Finance (MEAF) or his authorized representative;
    • (ii) in case of Hungary, the Minister responsible for tax policy or his authorised representative;
  • (j) the term "national", in relation to a Contracting State, means:
    • (i) any individual possessing the nationality of that Contracting State; and
    • (ii) any legal person, partnership, association or other entity deriving its status as such from the laws in force in that Contracting State;
  • (k) the term "business" includes the performance of professional services and of other activities of an independent character carried on by any person.

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