PROTOCOL
PROTOCOL TO THE AGREEMENT BETWEEN THE REPUBLIC OF SLOVENIA AND THE ISLAMIC REPUBLIC OF IRAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
At the moment of signing the Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, this day concluded between the Republic of Slovenia and the Islamic Republic of Iran, the undersigned, being duly authorized thereto, Have agreed upon the following provisions which shall be an integral part of the Agreement.
(1) With respect to paragraph (3) of Article 2:
The terms "property tax" and "tax on property" shall not include inheritance tax.
(2) With respect to paragraph (3) of Article 11:
It is understood that the term "Government of the other Contracting State" in the case of the Islamic Republic of Iran includes ministries and other Governmental institutions. Furthermore, the term "local authority" means "municipalities".
IN WITNESS WHEREOF, the undersigned, duly authorized thereto by their respective Governments, have signed this Protocol.
DONE in duplicate in Tehran, this twentieth day of September 2011, corresponding to 29 Shahrivar 1390 Solar Hijra, in the Slovenian, Persian and English languages, all texts being equally authentic. In case of any divergence between any of the texts, the English text shall prevail.
FOR THE REPUBLIC OF SLOVENIA:
VLADIMIR GASPARIC
FOR THE ISLAMIC REPUBLIC OF IRAN:
ALI ASKARI