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)
    • (i) the term "Venezuela" means in its geographical sense, the territory of the Bolivarian Republic of Venezuela, including continental and insular space, lake and river, territorial sea, inland sea areas, including waters within the baselines straight taken or adopted by the Republic, the floor and subsoil thereof, airspace, continental and insular and maritime resources in them are, the continental shelf and the exclusive economic zone, the rights in outer space overlying, on which the Bolivarian Republic of Venezuela has or may have jurisdiction and sovereignty in accordance with their national law and international law;
    • (ii) the term "Islamic Republic of Iran" means the territory under the sovereignty and/or jurisdiction of the Islamic Republic of Iran;
  • (b) the term "a Contracting State" and "the other Contracting State" means the Bolivarian Republic of Venezuela or the Islamic Republic of Iran, as the context requires;
  • (c) the term "person" includes an individual, a company and any other body of persons;
  • (d) the term "company" means any body corporate or entity that is treated as a body corporate for tax purposes;
  • (e) 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;
  • (f) 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 places in the other State Contracting;
  • (g) the term "competent authority" means:
    • (i) in the case of the Bolivarian Republic of Venezuela, the Superintendent of the National Integrated Customs and Tax Administration SENIAT or his authorized representative;
    • (ii) in the case of the Islamic Republic of Iran, the Ministry of Economic Affairs and Finance or his authorized representative;
  • (h) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership or association whose status as such from the laws in force in a Contracting State.

(2) With respect to the implementation of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires a different interpretation, the meaning which it has under the law of that State for the taxes to which the Agreement applies.