PROTOCOL
In the moment of signing the Convention between the Government of the Bolivarian Republic of Venezuela and the Government of the Islamic Republic of Iran for the Avoidance of Double Taxation in Respect of Income Tax, the Contracting States have agreed that the following provisions integral part of the Convention.
With respect to Article 4:
It is understood that:
An item of income, profit or gain derived through an entity that is fiscally transparent under the laws of either Contracting State shall be treated as received by a resident of a Contracting State, to the extent that the item is considered for purposes of the tax laws of that Contracting State as the income, profit or gain of a resident.
IN WITNESS WHEREOF, the undersigned, duly authorized thereto, have signed this Agreement.
DONE in duplicate at Caracas on 11/03/2005, corresponding to 21/12/1383 (Solar Hijra) in Spanish, Persian and English languages, all texts being equally authentic. In case of divergence, the English text shall prevail.
FOR THE GOVERNMENT OF THE ISLAMIC REPUBLIC OF IRAN:
SEYED SAFDAR HOSSEINI
MINISTER OF ECONOMIC AFFAIRS AND FINANCE
FOR THE GOVERNMENT OF THE BOLIVARIAN REPUBLIC OF VENEZUELA:
TOBIAS NOBERGA
MINISTER OF FINANCE