The Turkish Grand National Assembly Warning: You Are Viewing The Law, Parliamentary General Assembly Accepted. If It Does Not Contain Any Changes That Are Made Later. The Council Of Ministers Of The Government Of The Republic Of Turkey And Serbia ...

Original Language Title: TÜRKİYE BÜYÜK MİLLET MECLİSİ Uyarı: Görüntülemekte olduğunuz Kanun, TBMM Genel Kurulunda kabul edildiği halidir. Varsa daha sonra yapılan değişiklikleri içermemektedir. TÜRKİYE CUMHURİYETİ HÜKÜMETİ İLE SIRBİSTAN VE KARADAĞ BAKANLAR KUR

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TURKISH GRAND MULLET

Warning: The Law you are viewing is considered to be accepted at the General Assembly of the TBMM. It does not contain any later delics if it exists.


 

THE TURKISH REPUBLIC GOVERNMENT AND THE CABINET OF CABINET MINISTERS ARRIVE AND FORTUNE IF APPROVED TAX AVOIDANCE IS APPROPRIATE FOR APPROVAL TO PREVENT DETECTION OF PREVENTING OUTPUT FROM THE TABLE

 

Kanun #5600

 

Acceptable Date: 13/3/2007      

 

MADDE 1- on 12 October 2005 "The Government of the Republic of Turkey and the Council of Ministers of the Republic of Turkey and the Council of Ministers of the Republic of Turkey and the Council of Ministers of the Republic of Turkey have agreed to the approval of the" Avoidance Of Double Taxation of Tax on Tax in Received Taxes.Üzerinden.

ARTICLE 2- On the release date of this Law It will take effect.

TICAD 3- Ministers of this Law Executes installed.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

REPUBLIC OF TURKEY GOVERNMENT

ILE

MINISTERS FROM THE CIRCUS AND THE BLACK INSTALLED

IN

SEARCH

ARRIVE AND RECEIVE A FORTUNE ON VERGES

UNTAX AVOIDANCE

UNDERSTANDING

 

 

REPUBLIC OF TURKEY GOVERNMENT

AND

MINISTERS FROM THE CIRCUS AND THE BLACK INSTALLED

 

Revenue and wealth with the desire to make a statement that prevents double taxation in taxes

 

TO UNDERSTAND THE CURRENT VARMISHLARAN:

 

 

Clause 1

CAPACITY COVERED

This means that one or both of the Skit States will have a meeting. will be applied to the system.

Article 2

KAVRANAN VERGALS

1. This means that no matter how much it is taken, it will come from a State or political subdivision or neighborhood administrations, and apply to taxes on wealth through wealth.

2. Taxes on the total amount paid or the total amount paid by the funds, including taxes imposed on earnings from the transfer of securities or real estate assets, and taxes imposed on capital of the capital, including Total income, total wealth or income, or all taxes, from the elements of wealth or wealth, will be considered as taxes from income or fortune.

3. Specifically, taxes that apply to the deal are applicable:

On

in Serbia and Montenegro:

Tax on

1);

vergi2) tax on revenue;

3) tax on wealth.

(This will refer to "Serbia and the Montenegrin tax");

in Turkey

1) income tax;

2) corporate tax;

(This will refer to as "Turkish tax").

4. At the same time, the statement will also apply to taxes that are applied in addition to or replace existing taxes after the date of signing of the statement, or which are substantially similar to existing taxes. The authorities of the Aşit States will report to each other the important depositions made in the relevant tax legislation.

Clause 3

GENERAL DEFINITIONS

1. For the purposes of this statement:

1) The terms "A State" and "State of the Union", according to the text widget Serbia and Montenegro or Turkey mean it;

2) The term "Serbia and Montenegro", states with Serbia and Montenegro Serbian and Montenegrin black country, domestic waters and territorial waters, while the air in which Serbia and Montenegro were used in the common sense, are in line with Serbia and Montenegro, its own internal law and international law. on the basis of the investigation and operation of the current resources. Use of sovereign rights refers to the sea bed and land of the hungry sea line left in the waters of the black waters.

3) The term "Turkey", including its territorial waters, and the air on it, The sovereignty area of Turkey refers to the field of jurisdiction or sovereignty that is used to search, process, and protect the relevant resources in accordance with international law; anddeniz

4) The term "political subdivisions" is in the state community in Serbia and Montenegro. refers to member states;

5) The term "Citizen":

-any real person who has a citizen of a Akkit State;

-any status that earns a status according to the legislation in effect in a Akite State legal entity, partner or association

refers to;

6) "Kishi" refers to a real match, a company, and a lot of people. includes any installation;

7) The term "February", as an institution in terms of any institution or taxation to any installation that is being treated;

8) "The contact of the State of a Kite State" and "the contact of the other Akite State" with the terms of the terms, a service that is being pushed by the machine of a Instrument State, and a contact that is being pushed out by the team of the Diaper Devlet Devlet;

9) The term "internationalistic traffic" is only the left of the other Skit State. refers to all types of shipping, aircraft or land transport, excluding the ship, aircraft, or land transmission board, which is being actualized.

10) "Authority for authority":

-In Serbia and Montenegro, the International Ministry of Economic Affairs, or authorized representative;

-In Turkey, the Ministry of Finance or its authorized representative

refers to.

2. Any term that is not defined in the expression, unless otherwise stipulate to the contrary, is used by the State of the State in the future, as a result of the implementation of the State of the Union in the case of the applicable taxes. The meaning of this term in the current tax legislation will be superior to the meaning given to this term in the other legislation of this State.

Clause 4

MUKOM

1. For the purposes of this, the term "a Instrument State" means that the State, including any political subdivision or neighborhood administration, has the state of residence, residence, legal center, place of administration or similar structure. it means the person who falls under the taxpayer due to any criteria. This term, however, does not include only the income from sources in that State or any other person who is subject to a tax due to the wealth in that state.

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 Sat Devices:

1) This is the state of the state where a home is located only to remain permanent. Will be accepted. If there is a permanent home in both Devlette, it will only be accepted by the state of the state, where their personal and economic relations are closer (the center of vital interest);

2) 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, the machine will be accepted for the state of the state where the home is not the only one to remain;

3) If there is a home in which the Eater is found to remain in both Develes, or if such a house is mentioned in both Devlette, it will only be accepted by the state of the state that it is a citizen of this country;

4) Both Devlets are citizens of both State or both State If it is a citizen, the authorities will resolve the issue of the authorities in the case of the authorities.

3. In the case of a real match, the 1st of the 1st storm provisions, the issue of the competent authorities of the Republic of Turkey, the authorities ' jurisdiction, the effective administration place, or any other relevant criteria of the city's office. And they will try to solve it with the understanding of the decision.

Clause 5

ISRAELÝÞYERÝ

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 included in the following:

1) Management location;

2) Feb;

3) Bureau;

4) Factory;

5) Workshop; and

6) Maden, oil or natural gas well, hot water or natural gas Any location where resources are grapeed.

3. A construction or installation project will generate an office where more than 18 months of progress is still in progress.

4. Any prior provisions of this clause will be considered to include the term "workplace":

1) The facilities, contact property, or commercial property of the facility are only storage, purpose, or delivery purposes;

2) Only storage, technical, or commercial stocks of the country belonging to the country. or, for delivery purposes;

3) Stock-in-goods or commercial stocks, only one bareka To be achieved with the purpose of being pushed to the country;

4) Sell business to only business or business if a fixed site is fixed retention, or collecting information;

5) that a stable place has been prepared only for the operation of the United States with the purpose of executing any other character, such as the execution of any other person;

6) A fixed place is mentioned only in (1) to (5) to execute a few of the activities together; however, it is the preparation or performance of the activity that is the result of the execution of all of these activities in the fixed place.

5. In a case where the provisions of the 1st and 2nd feats are removed, a team of people will act on behalf of a network and have the authority to deal with the name of a bus, in an agency that is not the first to implement a personal -- If using this authority, the activities of this person will not be available, as long as it is not in accordance with the activities described in the 4th frame and which do not place this place according to the provisions of this fikra, if the company is made of a fixed location. This is Devlette, any activity in which the person in question is real for the United States. It will be considered to have a location.

6. A United States van, a member of the United States, has a job in the state to conduct business with an ongoing trader, general commission agency, or any agency that has status as a candidate for any other agency in the state. It will not be.

7. A company, a member of the State of a âite, controls or controls a company that is either a member of the state, or in a commercial activity in this state, or if it is controlled by it, a company that is the member of the State of the World. Someone will not have an office for the other.

Clause 6

OBTAINED FROM GEYRISECURITIES GELIR

1. Income from real estate, which is in the case of a Profit State, is taxable (including income from agriculture or forestry), and it may be taxed in this other State.

2. The term "real estate" will be defined according to the legislation of 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. It will cover the rights of the Intifa rights and mines, sources and supply of resources and other resources, including ships, vassars, planes, and land transport, real estate, or other rights. It will not be accepted as an asset.

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 fikra provisions will also be applied to income from real estate assets used in real estate from the real estate entities, as well as income from a real estate entity.

Clause 7

FINANCIAL GAINS

1. The acquisition of a Profitable State for State community will be taxed only in this state, as it is not in commercial activity there, with a location in the office of the teleport, Akit Devlette, and the other. 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. In the event of commercial activity there, both in the Azoit Devlette were the same or similar conditions that would be attributed to the site, as the 3rd fikra provisions were held there by a site of the state's office in a State of the Republic of Azite, in the event of a State of the Republic of Azite. It would be a total gain, regardless of the fact that there was a service in the mirror or similar activities, and a full range of qualifications that would be completely different from the person who had been involved in the development and position of the company.

3. When determining a location, you will be allowed to download expenses that are appropriate for the purposes of the site, including management and general administration expenses, that are located on the site of the state or state where the location is located.

4. According to the legislation, there is no provision in the 2nd section of this article, in the case of the fact that it is mutable to be attributed to the various units of the country's total earnings, according to the legislation, in the case that it is mutable. It would not prevent the state from specifying such a payout method, which would be taxed. However, the method of sharing will be so that the result will be in accordance with the principles set out in this matter.

5. 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.

6. For the purposes of the previous fuses, the benefit attributed to a business is determined by the same method as each year, as opposed to a reasonable and current reason.

7. 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

INTERNATIONAL TRAFFIC

1. Earnings from the event of a State-led government transport, aircraft or land transmission in international traffic, will only be taxed on this state.

2. The use, maintenance, or leasing of any of the containers used in international traffic from the use, maintenance, or leasing of a Akkit Government loan has been used by this request for use in goods or commercial shipping. Only this will be taxed in this Azit State, with the need to do so in terms of the construction of ships or aircraft in international traffic. In other cases, the proceeds will be made according to the provisions of Article 7.

3. The 1st fikra provisions will also be applied to a partner, a partner, a partner or an international agency, as well as the proceeds from the transaction.

Article 9

RELATED CONTACT

1. 1) The management, control, or capital of the Minister of Government, or indirectly, in the form of a Monopoly State, or indirectly, or

2) An event of the State of the Union, or indirectly, as a result of the following: In the management, control or capital of the state's government, it is

and both, both commercial or financial services between the two teas Due to the conditions that must be caused by people who need to be among the people who need to be in one of these countries, but because of these conditions, the gain can be added to the benefit of that life, and the fact that it is not, it is the same. It can be taxed accordingly.

2. A State of the United States must include the earnings of the state's own private and tax taxation, include the earnings of the country's foreign policy, which should have been taxed at the same time, and the conditions required to be in the car for two weeks in a state of taxation. In the event of no gain as a result of the calculations made later in the United States, the other State will make the necessary corrections to the amount of tax received over that benefit if it is deemed to be in place of this specification. When making this correction, the other provisions of this statement will be taken into consideration, and the competent authorities of the United States will be consulted on the need.

Clause 10

THEMES

1. They were paid to a member of the State in a State of Love, a member of the State of the State, which may be taxed in this other State.

2. However, they may be taxed at the same time that the company made the dividend payment, in which it is a member of the Devlet and the State of the State, but the true beneficiary of the dividend is, in this way, the State of the World in which the State of the State is the true beneficiary. tax-on-tax rates will not be repaid:

1) The real beneficiary is the capital of the capital of the dividend payout. if a company that holds a minimum 25 percent (except for the partner), is 5 percent of the amount of the gross dividend;

2) 15 per cent of the amount of the gross dividend in all other cases.

This fikra is a dividend payment of dividend payout will not affect taxation.

3. The term "dividend", used in this material, is the state of taxation, based on the legislation of the state, which is based on revenues from other rights, which may not be in stock or credit, and the company that makes the profit off of the profit. Funds and yachts are being treated as per the laws of the State, which has received the same treatment as the proceeds from the bonds and the laws of the State, where the fund or partner has been treated as a basis for the laws of the state or the state of which they are treated as a basis for the laws of the state. the revenue that is obtained from the partner.

4. The winner of a commercial activity in commercial activity with an office located in the Diker Azite Devlette, after being taxed according to the 7th Amendment, is the 1st of the 2nd fund of this Article in the company in which the remaining part of the entity is located. Taxable in accordance with your own.

5. The true beneficiary of the dividend, a Combat Government team, is there in commercial activity there, where the company, in which the company pays the dividend, is found in commercial activity there, or a fixed place in the other state. if they are found in free professional activity and there is a significant view of this business or fixed place, the provisions of the 1st and 2nd fikra will not be applied. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

6. In order to retain the 4th Fükra provisions, a company with a State of the Republic of America acquired profit or revenue in the other State of the Union, and this is in the State of the Republic, with the acquisition of a dividend or dividend. cannot receive any tax on the dividend paid by this company, except when there is an active site in a location or fixed site, except for an active site. 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 Akite State and the other in the State of the World may be taxed on this other Devlet.

2. However, this interest may be taxed according to the Minister of Atkit and the State of the State; however, the real beneficiary of the interest is the 10% of the gross amount of your tax interest in this country. It will not.

3. Looking at the 2 nci fikra provisions, an interest in a Akitel State;

1) Government of the Republic of America, a political subdivision or a neighbourhood administration; or

2) the Central Bank of the Republic of America or the National Bank of the State

Data in this State if it is obtained by

as the actual beneficiary It will be exempt.

4. The term "interest" used in this material is derived from all types of creditless revenue and, in particular, bonds or debt bonds, regardless of whether or not to guarantee the mortgage guarantee or to contribute to the debtor. refers to the revenues and bonuses offered to the securities and bonds or bonds.

5. The true beneficiary of the interest in a Kite State team is found in commercial activity there, with a stable site in the country where the interest is obtained, or a fixed place in the state of the other, in a free business. If it is found and there is an active view of this office or fixed site with the payment of that interest, the provisions of the 1st and 2nd fikra shall not apply. In this case, the provisions of article 7 or 14th will be applied according to the event.

6. The interest paid by the perpetrator of a State of the State will be accepted in that State. However, the interest-paying person is either a member of a Kite State or has a fixed place, where the debt-to-credit relationship is causing the interest to pay off an interest in a Âkit Devlette, and interest is in place of this office or fixed place. This product will be considered to be obtained in the state where the site or the location of the site is located.

7. The amount of interest paid in the credit card will be determined in the real beneficiary between the payable or the actual beneficiary between both and the actual beneficiary, if not such a relationship. The provisions of this matter will only apply to the most recent amount of the most recently mentioned quantity. In this case, the additional payment will be taxed according to the legislation of each of the Azoys, under consideration of the other provisions of this statement.

Article 12

COST-OUT-OF-RIGHTS

1. The cost of an invigorate value, which is paid to a member of the Aper State and in the other, is taxed on this other Devlet.

2. However, the actual costs of money may be taxed according to the State and the State of the State, but the real beneficiary of the cost of the money is the tax, if the State is a member of the State of the Real. It will not charge 10 per cent of the gross amount of the cost of the gaysum.

3. The term "Gayrimaterial rights" used in this material is that of any kind of literary, artistic or scientific copyright, including radio or television records, as well as any kind of patent, any kind of patent, plan, or model, plan, or design. to use or use the secret formula or production method, or to use or use the right, commercial or scientific equipment, or to accumulate information on the right, commercial or scientific experience. Refers you to any payment.

4. The true beneficiary of the cost of an Akit State is the real beneficiary, if it is found in commercial activity there, or in a fixed place in the other state, in which the price of an entity is located in the Devlette state. If there is a free trade activity there, and there is an active line between the right or the default, 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. It will be accepted that the value of the purpose of the purpose of the purpose of the State of a State for the purpose of the purpose of the Government is to be achieved in that state. However, a person who pays the price for diligent eligibility, whether or not, has an obligation to pay the right to an illegitimate claim in a Kite State, has a fixed place or a fixed place and is entitled to an invigorate claim. The price will be obtained from this site or from the fixed site and will be accepted in the State of the State where the cost of the property or fixed place is located.

6. The amount of the amount of money that is paid in terms of use, right or information is real, because of the fact that there is no such relationship between the other and the actual beneficiary between the other or both, because of the special relationship that exists between both and one person. The provisions of this clause will only be applied to the most recently mentioned quantity, in the amount that will be determined in the dialeddar. In this case, the additional payment will be taxed according to the legislation of each of the Azoys, under consideration of the other provisions of this statement.

Article 13

CAPITAL DEARABLE EARNINGS

1. Earnings per share of the real estate entities, which are included in the 6 ncu clause, are taxable in this State of the Republic of Turkey.

2. Securities that are owned by the commercial entity, including the commercial entity of a Kite State team, including the commercial entity, or in the case of a Âkit State party to perform free business in the Aper Transfer State. Proceeds from the disposal of the assets may be taxed in this other State, including the benefit of this (either alone or with all contact), or from the disposal of the fixed site.

3. Proceeds from the disposal of the securities related to the operation of the ship, aircraft or land transmission and transport of the ship, aircraft or land transmission were sold in international traffic by a State team of Sitekit, Only this state will be taxed.

4. Profit from the disposal of the remaining assets of the 1, 2 and 3rd fives will be taxed only in the area where the result of the disposal of which is left-to-hand is the result.

Article 14

FREE TRADE INTEREST

1. A real person who is a member of the State of a State will receive free professional services or activities in which he/she has experience, will be taxed only in this State, but;

1) this is the continuous execution of the event in the Devlette Devlette. If it has a fixed location, then only the revenue that can be attributed to that fixed site can be taxed in this other, in the Azit Akut Devlette; or

2) this person, who is involved in the financial year related to the other in the other, or in the If a total of 183 days or more is left in any twelve months period, then only the proceeds from the activities performed in the Diyer in the Akkit State Circuit may be taxed on this other Devlette.

2. The term "free vocational services" is a scientific, literary, artistic, educational, educational, educational, professional, lawyers, lawyers, engineers, architects, workers, accountants. activities.

Article 15

PRINTED INTEREST

1. The provisions of the article 16, 18, 19, 20, and 21 are to be saved, and the fee, salary, and other such proceeds of a Profit Government team, shall be taxed only in this State, unless this service is performed in the other in the State of the Aper Atoll. If the service is performed on the other Devlette, the proceeds from here will be taxed on this other Devlette.

2. Looking at the 1-pearl provisions, a Profit Government team has achieved the right to a service in the State of the Republic, eyer:

1) Revenue resulting in the financial year related to the other Devlette or a total of 183 days at a time, in any twelve months period, and

2) Payment by an informal or non-conserved state of the other State. if an issuing name is called, and

3) Payment is either from an existing state or fixed term that the business has in the other from the location, if notkaynaklanmazsa

will be taxed only on the first mentioned Devlette.

3. This is the transfer of a service that was executed in international traffic, a ship, aircraft or land transmission in international traffic, regardless of the prior provisions of this clause. taxable.

4. The revenue of this Article, obtained by a State of the Republic of Turkey, is a development, construction or installation of the following income, which does not include the provisions of the 3rd section of the 5th Amendment, in which case the provisions of this Article are made. if it is paid for by a service that is being executed in this Devlette Devlette, only this Devlette will be taxed.

Clause 16

PAYMENTS TO MANAGERS

A policy of the State team, which is a member of the State's State of America. as a member of the board of directors, fees and other such payments may be taxed on this other Devlette.

Article 17

ARTIST AND ATHLETES

1. In order to look at the provisions of 14th and 15th articles, an artist or a musician, such as theatre, cinema, radio or television artist, who is a member of the State of the Republic, or an athlete, in the event of the activities of the other Akit Devlette, the activities of the actor or the artist. They get it, it's taxed on this other, in the Devlet.

2. If an artist or athlete's performing business comes from activities, whether the artist or the athlete himself is directed to a woman, the income is 7, 14, and 15, the artist or the athlete's. the Akit Devlette, which is performed by its activities, is taxable.

3. Looking at the provisions of the 1st and 2nd feats, an artist or athlete with a State of the State who is a member of the Council of America, the activities of such activities, in both of the countries of the Republic of Turkey, have been approved. Or if it is performed within the framework of a sportive program, it will be taxed only in this State.

Article 18

RETIREES AND REGULARS

1. The provisions of the 19th Amendment are intended to remain withheld, with pensions paid for by the passage of a Turkish State team, and regular payments for life, only in this State of State. will be taxed.

2. The term "regular payment" is a lifetime or a certain amount of time to be paid periodically, at certain times, depending on the obligation to pay full and sufficient payment in a monetary or money-quantifiable benefit. the sum of the sum.

Article 19

PUBLIC TASK

1. 1) A Service is paid by a real party to a political subsection or a neighborhood administration that is paid by the State, subdivision or administration and the pension is the remaining wage, salary, and other payments will be taxed only in this Devlette.

2) However, the service is being performed in the other Akkit Realm, and is real When the government is a member of that state, the fee, the salary, and other similar payments will only be taxed in this other State. However, this is:

-being a citizen of this State; or

-state of this state to execute only the service in question. geçmemiþ

is required.

2. 1) This is the only time that a State of America government, a political subdivision, or a neighborhood administration or funds that have been created, paid for a real time in the service of this State, the subdivision or the administration. Will be taxed in the state.

2) However, the real world is a member of the State of the AzoKit If it is not a citizen, the pension will only be taxed in this other-in-the-place, Azit Devlette.

3. A State of the State itself, a political subdivision, or a neighborhood administration with commercial activities, the fee, salary and other similar payments, and pensions of 15, 16, 17, and 18 are the same The provisions of this document are applied.

Article 20

OTHER REPOSTED

1. For the cost of livelihood, livelihood, or professional education, whether at the time of a visit to the State of Akili or just before, a student or intern who is the primary and first mentioned State of the Republic, only to be found in the State of the Republic or the other person who has professional training. Payments made from government sources will not be taxed in this State.

2. In terms of payments made from non-closing statements, scholarships and non-grapetable purchases, the 1st of which is a student or intern mentioned in the 1st storm, for whom they visited, during the course of my life or professional education. They will also be eligible for the same exemption, exception, or discounts.

Article 21

PROFESSORS AND RESEARCHERS

1. A State of Love, a university in this State, a school, school, or other general admission to the public institutions that I pay or visit with the purpose of a visit to and from this visit immediately before or immediately preceding the visit of the Aper Event. the current revenue from the state in which the actual business is not two years away from the date of the first visit to this State for the purpose of this State, is the first time the State has been mentioned in the is the exception.

2. For the sake of public interest, the 1st frictions provisions of this Article shall not be applied to the revenues obtained, especially in the interest of the specific individual or the interests of the people.

Article 22

LANGUAGE GELS

1. Some of the revenue elements that are not stated in the earlier articles of the State of a Akkit Government will be taxed only in this Devlet.

2. Excluding the income derived from real estate assets described in the 2nd of six articles of matter, the beneficiary of that income is a beneficiary of that income, in the case of commercial activity there, in the other in the Turkish, in the other, in the case of the real estate. If a fixed place in the other Devlette is found in free professional activity there, and there is an active view of this office or fixed site with the right or the right to pay for the income, the 1st frisk provisions will not be applied to this income. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

Article 23

FORTUNE

1. The wealth of real estate assets, which is mentioned in Article 6 of a Akkit State team, is taxed in the other Devlette.

2. A securities of the Securities of a State property, including the active part of a State-owned business, or a fixed place in which a State team can use it to conduct free business in the Akkit Devlet. A wealth of assets can be taxed on this other State.

3. The ship, aircraft or land transmission vassing along with the ship, aircraft or land transmission vassing, a fortune in the State of the Republic of Turkey, is a wealth of securities related to the operation of aircraft or land transmission, only in this State. will be taxed.

4. All the wealth elements of a Âkit Government team will be taxed in this state alone.

Article 24

PREVENT TAX VERITABLE

1. In accordance with the provisions of this Ruling State, the first mentioned State, or in possession of a wealth of income or wealth of wealth, is the State of the Union;

-the revenue that hits the revenue of this contact is paid in the other State If you want to add a value to the tax,

-the wealth that was paid in the fortune of this candle, paid in the other Amount a value to the tax

will allow the mashup.

However, in both cases, the other Devallette It will not increase the amount of income or wealth tax that can be taxable, income or attributed to the asset, calculated prior to the maphsupate.

2. In accordance with the provisions of this State, the income or wealth obtained by a Convenience Government must be exempted from this State, while this State calculates the tax of the remaining income or fortune of this person. can also consider revenue or fortune.

Article 25

SEPARATION OF SEPARATION

1. A State of the State's citizens, in the other part of the State of the World, say that their citizens, especially in the direction of the government, are less likely to tax or leave taxes, or more, whether or not they are involved in the future. They will not be subjected to taxation or to those who are not subject to it. This provision will be applied to the non-conunuate of one or both of the States, regardless of the 1 th provisions.

2. In order to hide the provisions of the 4th section of the 10th Amendment, a State of the State's foreign policy, in the other State of the Republic of Turkey, has less lehe than those who have carried out the same activities in the other state, in the other state. It won't be up to you.

3. The interest of a State of the Republic of Turkey, except for the exceptions of the provisions of the 7th of the 11th Article, the 7th of the 11th Article, or the provisions of the six of the 12 articles of Article 11, is the interest paid to a member of the State of the Republic of Turkey, the interest of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the country. In the determination of the taxable earnings of this country, such payments will be able to be downloaded as if they were made to a member of the state, first mentioned in the same conditions. In the same way, in the determination of the taxable wealth of a State government, the debt of the country's taxable wealth, in determining the taxable wealth of this country's taxable wealth, was made with a team of the state's first mentioned state. will be downloaded.

4. The first mentioned State of the State of a State of the World, in which one or several parties of the State of the World, in the State of the Azite, or its fully capitalising, or whose capital is controlled, is the State of the State of the State. They will not be subject to the taxes or taxation of which they are subject or possible, or they will not be subject to taxes or other liability.

5. The provisions of this clause will not be understood as to apply the discounts, taxes, and matrah discounts to the State of a Akitel State, as well as to apply the tax and matrah discounts to their mukits.

6. The provisions of this clause shall be applied to the taxes mentioned in the 2 nci clause.

Article 26

BUSINESS MANAGEMENT PROCEDURE

1. One person, in the case of one or both of the states, created or created a taxation that is not in accordance with the provisions of the State of the Union, is the procedure that is foreseen by the domestic legislation of the states. In the case of the authorities, the competent authority of the state in which the incident occurred, or in accordance with the 1st of the 25th Amendment of the situation, may supply the authority of the Minister to the State of the State of the State. The following will be done within three years of the initial declaration of an act that has resulted in a tax on the provisions of the Anthem.

2. If the authority finds the right to appeal, and cannot be resolved, he will make an effort to deal with the competent authority of the country, in an attempt to avoid a further taxation of the State. Any considerations will be applied to the time left in the domestic legislation of the states in the United States.

3. The competent authorities of the Aşit States will strive to resolve any strong or hesitation arising out of the interpretation or implementation of the State of the Union. 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 State States can communicate with each other, including a commission from themselves or their representatives, in order to reach the understanding of the previous funds in the previous fats.

Article 27

EASY TO DEAL WITH THE BUSINESS

1. The competent authorities of the State States are required for the execution of the provisions of the internal legislation relating to the duties of the Union, unless they have the information or the compliance with the information required for the execution of the provisions of this Statement. They're going to put the information on my desk. Information source is left out of the 1 th clause. Any information received by the State of the State shall be confidential, such as information obtained within the framework of that State's own internal legislation, and only with the tax or penalty enforcement or penalty of the taxes specified in this statement, or the law. 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. These people or authorities will only use the information in the form of these purposes. These people or authorities can open such information in court proceedings or when they are making judicial decisions.

2. The 1st fikra provisions, a State of the Azoth in no way:

1) to the legislation or administrative applications of the Keni or the other the administrative precautions that will not fit;

2) Legislates or normal administrative actions of the Keni or other submission of information that cannot be obtained within the frame;

3) How to make any commercial, sanni, professional or commercial public giving information that brings information or ownership to the public order;

cannot be interpreted to put it under the obligation.

Article 28

OFFICERS ON THE CHARGE OF THE PLOMATHÜVÝYETÝNDEKÝ

AND CONSULAR OFFICERS

The provisions of this statement are either civil servants or consulates on a diplomat's government. It will not affect the financial details of the civil servants ' general rules of law or the provisions of special understanding.

Article 29

CURRENT LEAVE

1. The United States will inform each other in a diplomatic way, in a diplomatic way, that the work envisioned in their domestic legislation will be completed in order for this to take effect.

2. This statement will take effect at the time of the last of these notices, and the provisions of the calendar year that follow the current entry, in terms of taxes, which are owned by taxes on the proceeds. provision for each fiscal year or taxation period that will start on the first day of the month or later.

Article 30

CURRENT WITHDRAWAL

This information is in effect until it is dissolved by a Âkit State. It will stay. Each of the States can annully by issuing diplomatic means at least six months prior to the end of any calendar year after the current date of the beginning of the current date of the State. In this case, the Meaning is every fiscal year that follows the first day of January or later of the calendar year following the termination of the annulment of the annuials, which are owned by taxes, as well as for the acquired revenues. will not be sentenced for the taxation period.

 

 

 

 

 

 

 

PART OF THESE SERVICES, Fully qualified representatives who have signed up to sign this statement.

In two original, Turkish, Sürp, and English languages, both The original text was conducted in Belgrade on 12 October 2005, as well as the original text. English text will be valid if it is no different from the comment.

 

 

 

 

      REPUBLIC OF TURKEY CIRCUS AND TERRESTRIAL

ON BEHALF OF THE COUNCIL OF MINISTERS ON BEHALF OF THE

            GOVERNMENT

                         (Israel)