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, as the context requires, the Tunisian government and the Islamic Republic of Iran;
  • (B) the word "Tunisia" means the territory of the Republic of Tunisia, including areas adjacent to the territorial waters of Tunisia on which, in accordance with international law, Tunisia may exercise rights with respect to the sea bed, sub- subsoil and their natural resources;
  • (C) the term "Iran" means the territory in which the Islamic Republic of Iran has sovereignty or jurisdiction, and includes its maritime zones and in accordance with international law;
  • (D) The term "person" includes an individual, a company and any other body of persons;
  • (E) the term "company" means any-body corporate or any entity which is treated as a body corporate for tax purposes;
  • (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 and an enterprise carried on by a resident of the other Contracting State of a State;
  • (G) the term "national" means:
    • (i) all individuals possessing the nationality of a Contracting State;
    • (ii) all legal persons, partnerships, associations and any other entity organized under the laws in force in a Contracting State;
  • (H) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise which has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between situated in the other Contracting State;
  • (I) the term "competent authority" means:
    • (i) regarding the Tunisian Republic, the Minister of Finance or his authorized representative,
    • (ii) regarding the Islamic Republic of Iran: the Minister of Economic Affairs and Finance or his authorized representative.

(2) For the purposes of the Agreement by a Contracting State, any term not otherwise defined shall have the meaning ascribed to it by the law of that State concerning the taxes covered by the Agreement, unless the context requires a different interpretation.