Iran Tax Update

Analysis

Slim Gargouri provides an update on tax developments in Iran

Tax treaty between Indonesia & Iran: Effective from January 2011

Signed in Jakarta on 30 April 2004, the bilateral convention for the avoidance of double taxation between Indonesia and Iran applies starting 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 a business in the other Contracting State.

The term ‘permanent establishment' likewise encompasses:

a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than 6 months.

the furnishing of services, including consulting services by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregating more than 183 days within any twelve month period.

Dividends