This document is the Double Taxation Relief (Iran) Notice, 2012, which declares the arrangements made between the Government of the Republic of Kenya and the Government of the Islamic Republic of Iran for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital. The agreement was signed on May 29, 2012, and the notice was made on February 24, 2014.Taxes Covered (Article 2)The agreement applies to taxes on income and capital. The existing taxes are:

• Islamic Republic of Iran: The income tax and the property tax.

• Republic of Kenya: The income tax chargeable in accordance with the Income Tax Act, Chapter 470 of the Laws of Kenya.

  It also applies to any identical or substantially similar taxes imposed after the date of signature.

Key Taxation Provisions

• Dividends (Article 10): May be taxed in both States, but the tax charged in the company's resident State shall not exceed 5% of the gross amount if the recipient is the beneficial owner.

• Interest (Article 11): May be taxed in both States, but the tax charged in the State where it arises shall not exceed 10% of the gross amount if the beneficial owner is a resident of the other State. Interest derived by the Governments, Central Banks, or wholly owned institutions of the other State is exempt from tax in the State where it arises.

• Royalties (Article 12): May be taxed in both States, but the tax charged in the State where they arise shall not exceed 10% of the gross amount if the recipient is the beneficial owner.

• Business Profits (Article 7): Taxable only in the State of residence unless the enterprise has a Permanent Establishment (PE) in the other State.

• International Traffic (Article 8): Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State where the place of effective management is situated.

Elimination of Double Taxation (Article 23)

• Islamic Republic of Iran: Shall allow a deduction from its tax on income and capital for the tax paid in Kenya, up to the amount of Iranian tax attributable to that income or capital.

• Republic of Kenya: Shall allow a credit against its tax on income or capital for the tax paid in Iran, up to the portion of Kenyan tax attributable to the income which may be taxed in Iran.