background image
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 terms "a Contracting State" and "the other Contracting State" mean the Islamic Republic of Iran or the Syrian Arab Republic as the context requires;
  • (b)
    • (1) the term "Islamic Republic of Iran" means the territories under the sovereignty of the Islamic Republic of Iran;
    • (2) the term "Syria" denotes the Syrian Arab Republic in its geographical sense, which means the territory of the Syrian Arab Republic including the territorial sea, the continental reef, the subsoil, the air space above it and all other areas outside the Syrian territorial sea within which, in accordance with international law, Syria exercises sovereign rights for the purpose of extracting and exploiting the natural, vital and mining resources and all other rights in the water, on land and under the seabed;
  • (c) the term "person" includes an individual, a company and any other body of persons;
  • (d) the term "company" means anybody corporate or any entity which is treated as a body corporate for tax purposes;
  • (e) the term "registered office" means head office registered under the relevant laws of either Contracting State;
  • (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 operated by an enterprise of a Contracting State, except when the ship, boat, aircraft or road vehicle is operated solely between places in the other Contracting State;
  • (h) the term "tax" means any tax covered by Article 2 of this Agreement;
  • (i) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, deriving its status as such from the laws in force in a Contracting State;
  • (j) term "competent authority" means:
    • (i) in the case of the Islamic Republic of Iran, the Minister of Economic Affairs and Finance or his authorized representative;
    • (ii) in the case of Syria, the Minister of Finance or his authorized representative.

(2) As regards in the application of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which the Agreement applies.