Key Benefits:
TURKISH REPUBLIC GOVERNMENT TO COME BETWEEN THE GOVERNMENT OF BAHRAIN ' S KINGDOM ANTI-TAX EVASION AND TAX EVASION
CONFIRMING THE UNDERSTANDING OF OBSTRUCTION
APPLICABLE LAW APPROPRIATE LAW
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Kanun No. 5629 |
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Accepted Date: 25/4/2007 |
MADDE 1- 14 Kahm 2005 "the Government of the Republic of Turkey and the Government of the Republic of Bahrain on the Land of the Republic of Bahrain to Prevent Double Taxation and Preventing Tax Evasion in the Land of the Republic of Turkey," signed in Manama on the Arab Republic of Turkey. It is appropriate to approve the deal.
MADDE 2- This is the release of the Law is effective in its history.
MADDE 3- This Law The Council of Ministers executes its provisions.
PROCESS THE REPUBLIC OF TURKEY GOVERNMENT
KINGDOM OF BAHRAIN GOVERNMENT
EXIT DATA RECEIVED FROMVERGLET
AVOIDING PREVENTION AND VERGI
UNDERSTANDING THE OBSTRUCTION
REPUBLIC OF TURKEY GOVERNMENT
AND
KINGDOM OF BAHRAIN GOVERNMENT
Tax avoidance on double taxation in taxes received overTagPreserver,p,0,159Revenue and tax If you want to make a statement that prevents you from being a fugitiveARE AVAILABLE TO UNDERSTAND:
I.I. SECTIONSCOPE OF UNDERSTANDING
Clause 1
CAPACITY COVERED
This means that one or both of the Akit States will have a meeting. will be applied to the system.
Article 2
KAVRANAN VERGALS
1. This will apply to taxes on income from an Akit State, political subdivision, or neighborhood administrations, regardless of how much it has been taken.
2. Aggregate taxes, including taxes levied on the total amount paid by the securities and taxes imposed on earnings from the transfer of real estate or real estate assets. income, or all taxes received over the elements of the income, will be considered as taxes received over the income.
3. Specifically, taxes that apply to the deal are applicable:
a) in Bahrain, the income tax paid for the 22/1979 number of Emir Hizis ("Oil") Tax ")
(This will refer to "Bahrain tax".)
b) in Turkey:
i) income tax; and
ii) corporate tax
(This will refer to as "Turkish tax").
4. At the same time, In addition to existing taxes after the date of signing, it will also be applied to taxes that are applied to or substantially similar to existing taxes or similar taxes. The competent authorities of the United States will report to each other the important depositions made in their own tax legislation.
.II. SECTIONDEFINITIONS
Clause 3
GENERAL DEFINITIONS
1. From the purposes of this task, unless the text is predicted to the contrary:
a) i) the term "Bahrain" is the sovereignty area of the Kingdom of Bahrain, statements that use the rights of sovereignty and jurisdiction over Bahrain in accordance with international law, the seabed and the territory of the sea;
ii) The term "Turkey" is an area of Turkey's sovereignty, territorial waters. to address the international law, including the jurisdiction or the jurisdiction of the international law, or the rights of sovereignty, including the rights of the judiciary and protection of the rights of the international law, including;
b) "An Akit State" and "other Akit State" terms, according to the text of the Refers to Bahrain or Turkey;
c) The term "tax" is any tax that is used in the 2 nci clause of this Statement meaning;
d) the term "Kishi" refers to a real winter, a company, and a lot of people. includes any installation;
e) the term "February" as an institution in any form of institution or taxation. any organization that is being treated, or any organization that is installed or identified as an institution by the laws of one or other of the States, or any other organization that is known as the institution;
f) The term "Citizen":
i) all actual people with an Akit State citizen;
ii) the entire provision of status according to the legislation in effect in an Akit Devlette Partners, associations, or associations
refers to;
g) "The contact of an Akit State" and the "contact of the other Akit State" terms with the order of an Akit government, an operation that is being pushed by the machine of an Akit State, and a service that has been pushed out by the team of the other Akit Devlet;
h) "Authority for authority":
i) in Bahrain, the Minister of Finance or its authorized representative; and
ii) in Turkey, the Ministry of Finance or its authorized representative
refers to;
i) The term "international traffic" is only within the sars of the other Akit State. Except for the fact that the aircraft or land transmission is a reality, an Akit State team has been able to transport ships, planes or land transport. statements.
2. Any term that is not defined in the Meaning of any term, unless otherwise stipulate to the contrary, is the applicable taxes that are applicable to the application of this Agreement. from the point of view, the meaning of this state in the state of this state, and the meaning of this state in the current tax legislation, in terms of the meaning given to this term in terms of this term They're going to be on top of it.
Clause 4
MUKOM
1. From the purposes of this statement, the term "an Akit State" is the term,
a) in the Bahrain direction, One or more of the relevant fiscal years, one or a few at a time in Bahrain, is a real person in Bahrain, or a company or other, established in Bahrain, or in Bahrain, the central government of Bahrain. legal entities;
,b) In the direction of Turkey, The Turkish legislation provides a taxpayer with a taxpayer due to any criteria in the house, residence, the main centre, the administration place or similar structure.refers to.
However, this term only comes from resources in an Akit State or The capital does not include any money that is being subject to tax due to increased earnings.
2. The state of the following will be determined in the case of the first of the 1st storm provisions, as well as the actual performance of both the Acts of the Acts:
a) This is the state of the state where a home is only permanent. Will be accepted. If there is a home that will remain permanent in both Devlette, it will be accepted by the state (central to vital interest) of the state where their personal and economic relations are more closely related;
b) State of the center of the vital interests of the Euca. if it cannot be determined, or if there is no permanent home in both Devlette, it will only be accepted by the state of the state where the home is not the only one to remain;
c) If there is a home in both Develes, or both Devlette, if such a home is not mentioned, this will only be accepted by the state of the state of which it is a citizen:
d) Eater is a citizen of both State or both Devlets If it is not, the authorities of Akit will resolve the issue with the understanding of the problem.
3. When both Akit Deletions are part of a real match, the first of which is the effective management center of the State of Akit, it will be accepted by the state of the state. However, it is the law of the city in which the authorities of Akit States are in charge of the active management center in one of these states, with the authority of the authorities in charge of the main center of the city. will meet each other to determine whether or not the center will be considered the actual effective management center.
Clause 5
ISRAELTagPreserver,b,201,205
1. For the purposes of this, the term "workplace" refers to a fixed place where the business of a private business is fully or completely executed.
2. The term "workplace" is specifically covered by:
TagPreserver,p,0,159a) Management location;b) Feb;
c) Bureau;
d) Factory;
e) Atele;
f) Maden, oil or natural gas well, overflow or natural resources. Any location where it is located;
g) Rafineri;
h) the location of the Sat.; and
i) A storeroom that belongs to a person that provides storage services for their service.
3. For a period of 9 months, a project of construction, construction, or installation will become a site.
4. Any prior provisions of this clause will be considered to include the term "workplace":
a) Your facilities, contact property, or commercial property is only storage, purpose, or delivery purposes;
b) Only storage, contact, or delivery of the goods or commercial stocks that belong to the country. retention:
c) If the goods or commercial stocks belonging to the country are only a form of contact retention with the purpose of being done;
d) import only if a fixed location is a business or commercial property or collecting information for purposes of collection;
e) only prepared or helped a stable site for the operation of a stable location a character set to be made with the purpose of doing any of the following;
f) A fixed location is mentioned only in (a) to (e) to execute a few of the activities together, but are prepared for the preparation or performance of the activity as a result of execution of all these activities at the fixed site. It does not.
5. An Akit Devlette, an Akit Devlette, is acting on behalf of a team of the other, with the provisions of the 1st and 2nd fikra provisions, an agency that is likely to apply a part of the six-six fikra provision. If it does, the application will be considered to have a location in the Akit Devlette, which is first mentioned in any activity in which this person is actuaried for the United States.:
a), due to the purchase of activities for the operation of goods or business for the operation As long as it is not clear, the first mentioned State will have the authority to deal with the name of the contact and use this authority from the mutaden; and
is not authorized to have such authority, but periodically, the service will be Any product that has shipped or placed an order, or the first mention of the business, contains a stock of goods or business products that are originally mentioned in the Devlette.
6. An Akit State community, the other Akit Devlette, is an ongoing trader, general commission agency, or any agency that has status on its own, only to its own business. The owner will not be accepted as an owner in this state for execution.
7. A company that is a member of the State of an Acit, a member of the other Akit State, or a company that is engaged in commercial activity in this other state (either in a workplace or in a different way), controls a company or its If it is controlled by it, each of these companies will not have a location for the other.
.III. SECTIONUNDUE DATA
Clause 6
RESULTING FROM GAYRISECURITIES
1. Income (including income from agriculture or forestry) from the real estate of Akit State may be taxed in this other State, including income from the estate of Akit Devlette.
2. The term "real estate" will be defined according to the legislation of Akit Devlet, the entity in which it is found. In any case, the term is real estate, real estate owned by real estate assets and livestock, and livestock, private law provisions, which are used in the forest, including its subsequent assets and livestock. will cover the rights of the indent rights and the mine quarrying, which will cover the rights of resources and other dod’ s fixed or current payments; ships and aircraft are considered to be real estate assets. will not be.
3. The 1st fikra provisions will be applied to the revenue generated from the use of real estate, leased or otherwise used in any other way.
4. The 1st and 3rd Fükra provisions are also derived from real estate assets and the income from real estate assets used in the invention of free business. it will also be applied.
Clause 7
FINANCIAL GAINS
1. The gain of an Akit State community will be taxed only in this state, as it is not in commercial activity there, with an office located in the other, Akit Devlette, the subject of the teleport. If commercial activity is found in the above mentioned commercial activity, it may be taxed in this other State, with the amount of earnings that can be attributed only to the amount of money that can be attributed to the business.
2. Both Akit Devlette will be attributed to the site, as the 3rd fikra provisions are in commercial activity there, with an Akit State contact, Akit Devlette, in a commercial operation there, as well as a site. The benefit is that we had a separate and similar operation under the same or similar conditions, as well as a number of different things, and a fully-started qualification that would have been a place of work. It will be a gain if it gains profits.
3. When determining a winner, the location of the site, including administrative and general administrative expenses, to reduce expenses that may be appropriate for the purposes of the site. will be allowed.
4. No proceeds will be made available to the office of this location only if it has been purchased for goods or trading on behalf of the service.
5. The provisions of this provision will not be affected by the provisions of this clause, as the benefit includes elements of income that are organized separately in other items of this statement.
Article 8
DENY, AIR, AND LAND VACATION
1. The gains from an Akit State campaign, aircraft or land transmission vassing in international traffic, will be taxed only in this state.
2. An Akit State team is shipping international traffic to international traffic. The proceeds will be taxed on the other Akit Devlette, but the tax will be reduced to 50% of this amount, which will be tax on this other.
3. The 1st and 2nd fikra provisions of this Article will also be applied to the proceeds of an associate, a partner, or an agency that has been executed between nations.
Article 9
SUPPORTED CONTACT
1. a) Management, control, or capital of the Akit State community, either indirectly or indirectly, in an Akit State contact, or
b) The same, indirect, or indirect, Akit State contact, and In the management, control or capital of the Diyer Akit State community,
and both, both commercial or financial services between the two teas, or are imposed The conditions that must be in one of those countries, unlike those who need to be among those who need to be among those who need to be among those people, are the ones that are not self-profiteers, the conditions that are not to be seen. It can be added to the earnings of the community and it can be taxed accordingly.
2. The fact that an Acit State has included the earnings of its own business and the taxation of taxation includes the earnings of the other state, which is taxed in the other Akit Devlette, and the two days of the same time. as a result of the conditions being considered as a result of the first-mentioned calculations, the state of this specification is in place, given the conditions that should be in the field of the first mentioned state. If it does, it will make the necessary corrections in the amount of tax it received over the benefit. By making this correction, the other provisions of this statement will be taken into consideration, and the competent authorities of Akit States will consult each other as needed.
Clause 10
THEMES
1. The dividend is paid to a member of the State of the Scorpion State, which is taxable in this other Devlette.
2. However, it may be taxed according to the Akit Devlette and this state's legislation, which makes the payment of dividend payment at the same time; however, the true beneficiary of the dividend is the true beneficiary. If the State of Akit is a member of the State, it will not address the proportion of the tax it will take in this way;
a) The real beneficiary is less than the capital of the dividend payout company. A company that holds 25 (excluding the partner) is 10% of the amount of the gross dividend.
b) 15% of the amount of the gross dividend in all other cases.
3. The term "dividend" in this material may be from shares, to intifa, or to instill, mining shares, constituent shares, or earnings. According to the state of the state, the company that conducts the company with revenues from other rights, has obtained from other company rights, which are treated as a result of the proceeds from taxation. refers to revenue.
4. The winner of an Akit State company, which is in commercial activity there, with an office in the other Akit Devlette, after being taxed according to the 7th Amendment, found its place over the remaining part of the It can be taxed in accordance with the Akit Devlette and the internal regulatory provisions of that State.
5. The true beneficiary of the dividend, which is an Akit State team, is that the company that pays the dividend is found in commercial activity there, or in this other state, if it is found in commercial activity there. If a fixed location is found there in free labor, and there is an active view of this business or fixed site, the provisions of the 1st and 2nd fikra are found. will not be applied. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.
6. A company with a State of Akit, an Akit State team, has gained profit or income from the company, as a result of the provisions of the 4th Fıkra provisions, which are paid for by the company. will not receive any tax. The exception of this is that these themes are paid to one of the other members of the state or have received the dividend and have an active relationship between an area of this state. In the same way, this state cannot receive a no-profit tax due to the unimposed earnings of this company. Whether or not the selected dividend or revenue gain is entirely or revenue does not result in a profit or revenue earned in this Devlette state.
Article 11
FAIZ
1. The interest paid to a member of the Akit Devlette and the other Akit State may be taxed on this other Devlette.
2. However, this interest may be taxed in the interest of Akit Devlette and the State of the State; however, the real beneficiary of the interest is the tax, interest, which will be taken in this way, if the State is a true beneficiary. It will not waste 10 percent of your gross amount.
3. The term "interest", used in this material, is a matter of interest to the mortgage guarantee or recognition of the debtor, any kind of revenue that is owed, and in particular, public securities. The proceeds from the bonds or debt bonds, as well as bonuses and bonuses for the securities, bonds or debt bonds, and the tax legislation of the State obtained at the same time as a result of the tax legislation. For example, all revenue is expressed.
4. The real beneficiary of an Akit State team is if it is found in commercial activity there, or a fixed place located in this other Devlette, where it is located in the Akit Devlette, where the interest is obtained. If there is a free professional activity there, and the interest in question is to be paid, the 1st and 2nd fikra provisions will not be applied if there is an active view of this place or fixed place. In this case, the provisions of article 7 or 14th will be applied according to the event.
5. An Akit State itself, its political subdivision, its neighborhood administration, or the interest paid by a member of this State, will be accepted in that state. In addition, the interest-paying job is whether or not an Akit State has a relationship or a fixed place with its debt-to-credit relationship, which is causing interest to pay off an Akit Devlette interest. will be considered to be acquired in the Akit Devlette, where the interest, location, or fixed location is located, in the location of this location or fixed location.
6. The amount of interest paid in the credit card, the actual beneficiary between the payable or both of them, or both due to the special relationship between them and the other, is the payable and the beneficiary in the case of such a relationship. the provisions of this clause will only be applied to the most recently mentioned quantity, as the amount of time it is to be determined in the search. In this case, the additional payment will be taxed according to the legislation of each Acit State, under consideration of the other provisions of this Agreement.
Article 12
COST-OUT-OF-RIGHTS
1. The cost of an Akit Devlette and the non-monetary rights paid to a member of the other Akit State may be taxed on this other Devlet.
2. However, the value of the non-monetary rights in question is Akit. It can be taxed according to the state and the state of the state; however, the true beneficiary of the cost of the non-fallimaterial is the gross of the cost of the tax, which is the price of the tax, which will be taken in this way. will not be able to address 10% of the amount.
3. The term "Gayrimaterial rights," which is used in this material, is a literary, artistic or scientific kind of copyright, including films, bands and other images or audio reproduction tools. Any kind of patent, purchase, pattern, or model, plan, secret formula or production method, or use, commercial or scientific experience, either to use or use the method of production. for the accumulation of information, or any payment made by the use or use of the sannani, commercial or scientific equipment, or use of the use of the information.
4. The real beneficiary of an Akit State team is the real beneficiary, if it is found in commercial activity there, or in this other state, where it is located in Akit Devlette, where the price was obtained. If a fixed location is found there in a free profession, and there is an active view of the right or the other with the payment of the right or the fixed site, then the 1st and 2nd fikra provisions will not be applied. In this case, the provisions of article 7 or 14th will be applied according to the event.
5. An Akit State itself, its political subdivision, its neighborhood administration, or the cost of the amount of money that is paid for by a member of this State, will be accepted in that state. However, the person who paid the non-diligent right to an Akit State must or may not have the right to pay the price of an Akit Devlette, or to an Akit Devlet, to pay the price for an Akit Devlet. because of this or fixed place, the value of such an informal right, place or fixed place is acquired in Akit Devlette, where the price of the property or fixed place is located. From the top of the page.
6. The amount of the amount of money that is paid for in the right or information is due to the actual beneficiary between the other and the actual beneficiary, or both, for the purpose of such a relationship. The most recently mentioned quantity will be applied only when the actual beneficiary is determined between the boater and the actual beneficiary when it is not. In this case, the additional payment will be taxed according to the legislation of each Acit State, under consideration of the other provisions of this Agreement.
Article 13
CAPITAL DEARABLE EARNINGS
1. Earnings from an Akit State team, which is located in the other Akit Devlette and from the disposal of real estate entities that are specified in article 6, may be taxed on this other Devlette.
2. An Akit State team is about to operate a commercial entity, including a commercial entity, or Akit Devlette, an Akit State team, to conduct free trade in the country. Proceeds from an overhaul of securities that are used by a fixed site, including the benefit of this location (either with or with all contact), or from an overhaul of the fixed site , it may be taxed on this other Devlette.
3. A ship, aircraft or land transmission vassing, or ship, aircraft or land transmission vassing, were involved in international traffic by an Akit State concourse. Earnings from an overhaul will only be taxed in this Devlette.
4. An Akit State conunude of 1, 2, and 3-year-old officials said the remaining assets were sold in Akit Devlette, and other than those who had been left in the first state of the year. taxable.
Article 14
FREE TRADE INTEREST
1. In the event that an Akit State team has obtained free vocational services or other activities, it will be taxed only in this state. However, if these services or activities are performed in the other Devlette and the event is performed, the following:
a) to perform such services or activities in this other Devlette if it has a fixed place that can be used regularly with the purpose; or
b), in this other Devlette, to perform such services or activities for a total of 183 days or more at any time in any 12 month period, if any,
revenue may also be taxed at this other Akit Devlette.
In such a case, the subject matter, or only the fixed place in question. The revenue from the service or activities performed during the current period of time may be taxed in this other State.
2. The term "free vocational services" is a scientific, literary, artistic, educational and educational activities carried out in particular as a result of these doctors, lawyers, engineers, architects, and others. It covers the activities of the workers and accountants.
Article 15
PRINTED INTEREST
1. The provisions of articles 16, 18, 19, and 20 are to be saved, and the fee for which an Akit State has been acquired through a service of a service is due, as well as the salary and other such revenue, unless the service is performed by the other Akkit Devlette. It will only be taxed on this state. If the service is performed on the other Devlette, then the proceeds from this will be taxed on this other Devlette.
2. Looking at the 1st pearl provisions, an Akit State team will receive a service from the other Akit Devlette, resulting in a service event, including:
a) Revenue in revenue, other Devlette, related financial year, or a total of 183 days in a time period that ends in any 12 month period, and
b) Payment by an informal or non-conserved state of the other State If the issuing name is done, and
c) Payment is either from an owner or fixed term that the owner has in the other state. if not from the location
will be taxed only on the first mentioned Devlette.
3. The previous provisions of this Article include a ship, aircraft or land transport, which was executed by an Akit State team, in which a ship, aircraft or land transport was executed in traffic. income, this is Akit Devlette taxable.
Clause 16
PAYMENTS TO MANAGERS
The management of an Akit State team, a member of the other Akkit State Fees and other similar payments that are obtained by the fact that they are a member of the board may be taxed on this other Devlette.
Article 17
ARTIST AND ATHLETES
1. An Akit State team of theater, cinema, radio or television art or musician, or an athlete, is an artist or musician, and an Akit Devlette executive, regardless of the provisions of the 14th and 15th articles. They come from the current activities, they can be taxed on this other State.
2. If an artist or athlete's executive income comes from activities, the income of the artist or the athlete is to the position of a seven, 14, and 15-point-old. The Akit Devlette, which is the executive of the artist or the athlete's activities, can be taxed in.
3. An artist or athlete's income from activities performed by an Akit Devlette, complete or complete visit of the State of Akit, the political subdivision, or If it is supported by the public funds of the neighborhood administration, this State will be exempted from the tax.
Article 18
RETIREES
1. The two nci provisions of the 19th Amendment are to remain withheld, with retirements paid for by the past and other such payments as defined in the 2nd of the article. The regular payments will be taxed in the state where the only person who received these payments is the person who received the payment.
2. The term "regular payment" is a lifetime or a certain amount of time, depending on the obligation to pay full and sufficient payment, in which a monetary or money may be measured in a measurable benefit. at times, it represents the total amount to be paid regularly.
Article 19
PUBLIC TASK
1. a) An Akit Devlete, political sub-section or services provided by a real party to the local government, subdivision or administration, and the remaining pension of the The salary and other such payments will be taxed only in this Devlette.
b) However, if the service is executed in the other Devlette and the actual person is The fee, the salary, and the other such payments will be taxed only in this other Akkit Devlette. However, this isTagPreserver,p,20,24
i) that this State is a citizen of this State; or
ii) not only did this state transition to a status of the state to serve this service
is required.
2. a) An Akit Devlete, a political subdivision or services provided by a real party to its neighborhood administration, this State is paid for by subdivision or administration or for the funds generated by Pensioners will be taxed in this state only.
b), however, is a mystery and citizen of the real world, Akit State. If it is not, the current pension will be taxed only in this other state.
3. An Akit State itself is retired with a salary, salary, and other similar payments due to commercial activities carried out by the political subdivision or the neighborhood administration. The provisions of the article 15, 16, 17, and 18 will apply to the members of the community.
Article 20
OTHERS AND OTHERS
1. On a visit to an Akit State, or just before, I go to an intern or an intern who is the person of the other Akkit Devlet, who is first mentioned in the State of the State, or in the name of my professional or professional education. Payments to be used for the cost of living or vocational training will not be taxed in the first mentioned Devlette, with these payments running from sources in this state to the right.
2. In the same way, two years ago, during a visit to the State of Akit, or immediately prior to the first mentioned State of the State of Akit, the State of Akit, or the State of the Union, was originally intended to make a living or scientific research. Revenue for a period of non-working duration or for durations obtained from the sources first mentioned in the State of the State, which is the first to be mentioned, is the first to be mentioned, or that of the investigation or effort. In the mentioned State, the data will be the exception.
Article 21
LANGUAGE GELS
1. In an Akit Devlette, and other elements of income that are not explicitly stated in previous articles, this state may be taxed on.
2. The revenue items that are part of the Two Akit Transfer include only the revenue. will be taxed at the Akit Devlette, where the person who achieved it is the mukim.
Article 22
PREVENT TAX VERITABLE
1. In accordance with the provisions of this Agreement, an Akit State has obtained an income that can be taxable in accordance with the provisions of this Agreement, the first mentioned State, the tax that hit the income of this candle, the other Devlette. The amount of income tax will allow for an amount of income tax.
However, the subject matter can be taxed on the other Devlette The amount of income tax, which can be attributed, will not take place prior to the crop.
2. In accordance with the provisions of this Agreement, if the income obtained by an Akit State team is exempted from this State, this State is exempt from calculating the tax of the remaining income of this person. income can also be considered.
IV. SECTION
SPECIAL PROVISIONS
Article 23
SEPARATION OF SEPARATION
1. The citizens of an Acit State, Akit Akit Devlette, say that the people in the same state of this state, especially in the direction of mutias, are untaxed and able to stay in the way of taxation. They will not be subject to taxation or otherwise, subject to a greater taxation or other liability.
2. In order to hide the provisions of the 4th section of the 10th Amendment, an Akit State community has an office in which it has an Akit Devlette, the other state, which operates the same activities as the other State. Fewer lehe would not be involved in a taxation than their current law.
3. The 1st of the 9th Article was a member of the State of Akit, except for the people of the State of the State, except for the provisions of the 6th of the 11th section, or the provisions of the Article 6 of the 12th Article. The interest, the cost of the illegitimate right, and the other payments, in the determination of the taxable income of the country, were made to a member of the State of the State, which is the first to be mentioned in the same terms. to be downloaded.
4. The first mention of an Acit State, a person or a few of the other parties of the state, either directly or indirectly, or whose capital is controlled by one or several of its capital, is the first to be mentioned. They say they are subject to the taxation of the state, or the taxation of which they may be, or whether they are required to either tax or pay for it or not. They will not be subjected to it.
5. These provisions are required to apply the discounts, taxes and matrah discounts to the State of the Akit State, as well as in the case of a State of the Akit State. It will not be understood.
Article 24
BUSINESS MANAGEMENT PROCEDURE
1. An Akit State conunude, In the domestic legislation of this State, whether one or both of the United States would create or create a taxation that is not in accordance with the provisions of this Anthem. The authority of the Acit State, which is the subject of the incident with the stipulate procedure, is authorized by the competent authority of the state, or to the 1st of the 23rd Article, the authority of the government of Akit, if it complies with the condition of the 1st. It may be necessary.
2. The official would find the right to appeal, and he would not be able to reach a satisfactory solution, but to avoid a further taxation, he said, to deal with the authority of the other Akit State. It will make an effort.
3. The competent authorities of the United States will strive to resolve any strong or hesitation-arising out of the interpretation or implementation of the statement. At the same time, the authorities can also dance to avoid double taxation resulting from situations that are not addressed in the situation.
4. The competent authorities of the United States can communicate with each other in order to reach an understanding of the issues outlined in the previous series of frisks. If verbal information is deemed necessary to reach the point of understanding, this vision can be conducted through a Commission channel that is one of the representatives of the authorities of Akit States.
Article 25
EASY TO DEAL WITH THE BUSINESS
1. As long as the authorities of the Acid States do not show incompatibility with the narrative, an Akit State is concerned with its political subdivisions, or civil rights, and taxes in all of them. They will be able to assist in the implementation and execution of the administrative and internal regulatory provisions of the Akit States, which are envisioned. Such information may be used to discuss, collect, and collect taxes, review and collect taxes, or review of tax or tax-related issues, or follow up information. It will cover it. The information shall be subject to the judgment in accordance with the provisions of this article and shall be subject to confidentiality provisions stipulate in the 7th of the Articles of this Article. Rights and protective provisions that have been made to the country with the laws or administrative practices of the State of the requested state do not prevent or delay effective information in an unnecessary way. is still being applied.
2. The State of the country is not required to provide information that is not in the savings or control of any of the provisions of the monarch, both in its own administration and in the area of the monarch.
3. For the purposes of this Article:
a) The term "public company" will be made easier for people to share. With the fact that it can be sold, the majority of its shares come to a meaningful sense of any company that is put in place in a generally accepted stock exchange. If the stock has been received or sold or otherwise sold by a group of yachtmen, the shares may be purchased and sold by the people.
b) The term "large part of the shares", the multinational voting power and the company It refers to the stock or its statements representing the other.
c) "General acceptance of accepted securities" refers to publicly traded shares. trading,
refers to any number of regulated loans, and specifically, Bahrain, Bahrain. The Securities Exchange and Turkey's Istanbul Stock Exchange will express the Borsasi.
d) "Bulk fund or project" term, regardless of legal action, common refers to any type of sleep tool. The term "public public yacht fund or project" is used to ensure that the units, shares or other interests in the fund or project have been sold, sold or pushed for the public by the public. refers to any public yacht fund or project. If the units, shares, or other interests in the fund or project are received, sold or pushed through a group of yachts, the "public" may receive the purchase of the "public". can be sold or pushed.
e) The term "State" refers to the State of the State that is requesting information.
f) The term "demanded State" is the State of the State. meanings.
g) "Information gathering measures", the requested information of a State It means the laws and administrative or legal procedures that allow it to acquire and present.
h) The term "information" means any truth, statement, or record, regardless of the other way it is. b.
i) The term "criminal tax issues" is the subject of criminal justice for the state of the state. the tax issues that are related to the behavior of the person who can be done.
j) the term "criminal law", in tax laws, penal code or other refers to all criminal laws that are regulated by the provisions of the internal legislation, regardless of whether they are in the law.
4. a) The competent authority of the Minister of State shall provide information on the claim, from the maintenance of the purposes set forth in the 1st section of this Article. If the information that is subject to the review is made in the current state of the state, the claim is made by the state of the state of the claim, regardless of whether or not it will be criminalises in accordance with the laws of the state. It will be done.
b) Information in the competent authority of the state referred to, to meet the request If enough is enough, this State will provide all relevant information collection measures to ensure that it needs such information from its own tax purposes, to keep the information that is based on the state. will be used.
c) The competent authority of the state referred to in the state of the state of the state If requested specifically by the authorities, within this framework, the provisions of the internal legislation, in the Arabic, Turkish or English languages, the written statements and the original records of the tanks are not permitted. will provide information that is generated from the approved copies.
d) Each Akit State, the purposes set forth in the 1st frigid of this Article will be authorized to acquire and sell the information as specified in the office of the competent authorities in the request of:
i) Regents and trustees, banks, other financial institutions, and a Information that is in the hands of any other person acting in the agency or acting on the right-to-i fair amount;
ii) to companies, partners, trusts, foundation, and other kits. Property information, including property information for these people in a property writedown, under the 2-nci fund of the material, is the property of the trusts, the natives, trustees and beneficiaries of the property. information; and information on founders, board members and beneficiaries of the foundation. This article provides the ability to acquire and present property information relating to the Akit States, the public public or public public yacht fund or project without causing such strong power to be made. It doesn't have an obligation.
e), the competent authority of the state of the state of the state of the state of the state of the give the competent authority of the state to the competent authority to indicate that the requested information is relevant as a result of the request of the information;
(i) the identity of the judge, or the identity of the person who has been asked to do so;
(ii) The nature of the information and the claims of the state of the government To receive information from the government in what information and property;
(iii) What tax purposes for information is requested;
(iv) Authority of the requested state or state of the requested state in which information is requested The reasons why they found a person in their names;
(v) Each other person who is aware of the requested information, is aware of by-name and address;
(vi) The request of information to be used with the legislation and administrative applications of the state The requested information that it is compatible and appropriate to this item is within the jurisdiction of this state, which is the jurisdiction of this State's own legislation or administrative application. An explanation of how he would be able to obtain this information within the process;
(vii), except for those that may cause an extremely strong, refer-to-state a statement that it has taken all possible ways to get the information requested within their own country's left.
f) The competent authority of the State of the Claim may be requested And when it's done, it will send the state to the state that is doing it. To be able to respond to the claimed state's authority in a way that is:
(i) In 60 days after receiving the request, the person has received the request, based on The state must notify the competent authority as written, and must specify the deficiencies in the claim, if it is available.
(ii) The competent authority of the claim state, the information requested causes, including reasons such as the refusal to provide such information or refusal to provide such information, and will not be able to obtain and present the requested information within 90 days from the day of the request, if the request is not available Immediately informed of the reason for the reddance or failure to do so, and to address the nature of the challenges involved.
5. a) An Akit State Dier Akit Devlet's representatives of the competent authorities to question and examine actual people in the territory of the State, which is the first to be mentioned in the case of the relevant article. He could let him in with his goal. The aforementioned Second State shall inform the competent authority of the first mentioned State and the time and location of the visions to be made with the relevant real people.
b) At the request of the competent authority of an Akit State, diyer Akit authority may allow the representatives of the first mentioned state to be prepared in the appropriate part of the tax review conducted in the second State of the State.
c) (b) if the claim specified in the form is accepted, the Akit that executes the review The competent authority of the state, the location and the time of the review, the authority to conduct the review, or the procedures deemed necessary for the execution of the officer and the first mentioned State by the State They will report to the authority of the other state, in a way that is possible. All decisions related to the tax review will be received by the State that conducts the review.
6. a) The State of the Claim is required to obtain or provide information that is not available in accordance with its own laws, with the purpose of the administration and implementation of the state's own tax code. The competent authority of the State of the Claim may reject a request for assistance in accordance with this matter.
b) The provisions of this Article, an Akit State, commercial, sannum, or professional sr, or, it does not have the obligation to sell information that is in the event of a commercial action. The type of information that is specified in the 4 (d) itself of this Article cannot be treated as a sr or commercial operation only for the criteria specified in this section to the criteria specified in this matter.
c) provisions of this clause, a State of Acit, a lawyer with a prosecutor, a prosecution, or hidden messages between the legal representative, these messages;
Receive or sell a(i) legal advice service,
(ii) to be used in existing or ongoing legal action,
cannot force acquisition or acquisition or coercion to be installed with the purpose of the installation.
d) If the information is in public order, the State of the State can reverse a request for information.
e) A claim of information is the conflict in which the claim is the subject of the tax It will not be rejected.
f) Information, from the state of the government, which is based on its own tax code and The requesting state is not intended to implement or execute a provision that leads to a civil service, a provision that leads to an allocation of the state against the citizen of the state, which has caused the state to be involved in the if requested, the requested State may reverse this request.
7. Any information under this clause will be withheld by an Akit State, and only the tax or collection or case of the taxes specified in this Agreement or the case or case of this information. will be given to the office or authorities (including criminal authorities and administrative installs), which are tasked with looking at the concerns and objections of the people. Such information or authorities may use this information only in the case of such purposes. These people or authorities can open such information in court proceedings or in the process of making judicial decisions. The information cannot be opened to any other business, installation or authority or authority, without the permission of the reseller of the requested state to be written.
8. The United States will decide how to share expenses due to the help of the sale.
Article 26
DIRECT TO AVOID DATA TEDBALLER
1. An Akit Devlette dollar income is obtained by a person (excluding the actual person) who is the member of the other Akit State, and the non-team part of this other Akit State, or part of the business;
a) whether the direct or indirect, or where the contact may be, one or more If, in a partnership or other, a significant benefit from this part of the business; or
b) either direct or direct, manage, or co-manage, or The provisions of clause 10, 11 and 12 will not apply if they control the tax-exempt status or discount.
2. An important interest is at least 25% of the major capital of the company. status will be considered to be present.
Article 27
OFFICERS ON THE CHARGE OF THE PLOMATHÜVÝYETÝNDEKÝ
AND CONSULAR OFFICERS
The provisions of this statement are the officers and consulates of the diplomat's government. It will not affect the financial details of the civil servants ' general rules of law or the provisions of special understanding.
V. SECTION
FINAL PROVISIONS
Article 28
EFFECTIVE EXPENSE
Each Akit State is in its own internal legislation to make this effective notify the country of the diplomatic means that the envisioned process has been completed. This statement will take effect on the date of the last of these notices, and any taxation that follows the first day of January or later that follows the current effective entry. For taxes on the period of time, the sentence will be made.
Article 29
CURRENT WITHDRAWAL
This information is in effect until it is dissolved by an Akit State. It will stay. Each of the United States has diplomatic means at least six months before the end of any calendar year, following the current deadline, which follows the current deadline. It can be annuied by giving him a report of his own. In this case, the statement shall not be sentenced for taxes on any taxation period of the year January 1st or later of the year following the issuance of the annulment of the annulment.
This is a fully qualified representative for the signature of these HUSSEs. They signed the deal.
in Turkish, Arabic, and British languages, all three texts are equally valid. It is organized in Manama on November 14, 2005. Text in English will be valid if there is no difference between text. .
REPUBLIC OF TURKEY BAHRAINKRALLIÐI
GOVERNMENT NAME FOR GOVERNMENT
Aboration STATUEMEN Shaikh Ahmed bin Mohammed bin Mohammed AL KHALIFA
State Department Finance Minister
