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 23
Methods for the Elimination of Double Taxation
(1) In the case of the Islamic Republic of Iran:
- (a) Where a resident of the Islamic Republic of Iran derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Romania, the Islamic Republic of Iran shall allow:
- (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Romania;
- (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Romania.
- Such deduction in either case shall not, however, exceed that part of the tax as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Romania.
- (b) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of the Islamic Republic of Iran is exempted from tax in Romania, the Islamic Republic of Iran may notwithstanding the exemption, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
(2) In the case of Romania:
Where a resident of Romania derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the Islamic Republic of Iran, Romania shall allow:
- (a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in the Islamic Republic of Iran;
- (b) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in the Islamic Republic of Iran.
Such deduction in either case shall not, however exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital may be taxed in the Islamic Republic of Iran.