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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, the meanings of the terms are as follows:

  • (a) the term "Kyrgyzstan" means the Kyrgyz Republic. When used in the geographical sense the term "Kyrgyzstan" means the territory on which the Kyrgyz Republic carries out sovereign rights and jurisdiction in accordance with the International Law and in which the taxation laws of the Kyrgyz Republic are in force;
  • (b) the term "Islamic Republic of Iran" means the territory under the sovereignty and or jurisdiction of the Islamic Republic of Iran;
  • (c) the term "person" means:
    • (i) an individual;
    • (ii) a company or any other body of persons;
  • (d) the term "company" means any body corporate or any entity, which is treated as a body corporate for tax purposes;
  • (e) the terms "a Contracting State" and "the other Contracting State" mean the Kyrgyz Republic and the Islamic Republic of Iran as the context requires;
  • (f) 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;
  • (g) the term "international traffic" means any transport by a ship, boat, aircraft or road vehicle and railway operated by an enterprise of a Contracting State, except when the ship, boat, aircraft, or road vehicle and railway is operated solely between the places situated in one of the Contracting State;
  • (h) the term "competent authority" means:
    • (i) in the case of the Kyrgyz Republic, the Ministry of finance or its authorized representative;
    • (ii) in the case of the Islamic Republic of Iran, the Ministry of Economic Affairs and Finance or its authorized representative;
  • (i) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State.

(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 laws 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.