Tax treaty between Azerbaijan & Iran: Effective from January 2011

Signed in Tehran on 10 March 2009 and entered into force on 25 January 2010, the tax treaty between Azerbaijan and Iran applies from January 2011.

The main provisions of the treaty are as follows:

Permanent establishment

The term ‘permanent establishment' means a fixed place of business through which an enterprise of a Contracting State wholly or partly carries on the business in the other Contracting State.

A building site, a construction, assembly or installation project or supervisory activities in connection therewith, constitutes a permanent establishment but only where such site, project or activities continue for a period of more than 12 months.

Dividends

Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State, may be taxed in that other State.