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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 ETİ­YOP­YA FE­DE­RAL D

Read the untranslated law here: https://www.tbmm.gov.tr/kanunlar/k5599.html

Law No. 5599

Acceptance Date: 13/03/2007

Article 1 to 2 March 2005, signed in Addis Ababa, "the Republic of Turkey and the Ethiopian Federal Democratic Republic between the Government on Income of Double Taxation Agreement with Respect to Taxes" and the addition of the "Protocol" was found appropriate to approve reputation.
Article 2 of this Act shall enter into force on the date of publication.
Ministers executes the provisions of Article 3 of this Law.







REPUBLIC OF TURKEY AND THE GOVERNMENT OF THE FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA


BETWEEN INCOME TAX THROUGH THE DOUBLE TAXATION AGREEMENT in
GOVERNMENT OF THE REPUBLIC OF TURKEY AND



DEMOCRATIC FEDERAL REPUBLIC OF ETHIOPIA

Income in the tax on the desire to make an agreement to prevent double taxation
AS FOLLOWS HAVE AGREED
Article 1
PERSONS COVERED
This Agreement shall apply to persons who are residents of the Contracting State of one or both. Article 2 TAXES COVERED


1. This Agreement, irrespective of the manner in, a Contracting State or a political subdivision shall apply to taxes on income imposed by, or local administrations.
2. Securities or paid by enterprises with taxes on gains from the alienation of immovable property fee or including taxes applied to the total amount of the salary, the total income or any tax on income elements will be considered taxes on income. 3
. tax, which currently applies to the Agreement shall be applied in particular:
a) in Turkey:
i) the income tax
ii) the corporation tax;
Iii) the levy imposed on the income tax and corporation tax;
(Hereinafter referred to as "Turkish tax" will be mentioned);
B) Ethiopia:
i) services and taxes on income derived from the related fees;
Ii) income derived from agricultural activities, including real estate taxes on the rental income, which have a legal personality and taxes levied on income derived from non-business;
Iii) taxes on income derived from services performed abroad;
Iv) dividends, gayrimaddî royalties and taxes collected from gambling;
V) capital gains tax.
(Hereinafter referred to as "Ethiopian tax" will be mentioned);
4. The agreement also after the date of signature of the Agreement in addition to or in place of their existing taxes and the same quality as existing taxes or shall apply also to substantially similar taxes. The competent authorities of the Contracting States, significant changes made to their respective taxation laws shall notify each other. Article 3 GENERAL DEFINITIONS


1. For the purposes of this Agreement, unless otherwise defined therein shall:
a) i) the term "Turkey", the territorial waters and Turkey's territory, which includes the airspace above, exploration of natural resources as well as in accordance with international law, in order to operate and maintain It refers to the use of sea areas of jurisdiction or sovereignty;

Ii) "Ethiopia", the term Ethiopia when the Federal Democratic Republic and geographical terms used in the national territory and identified in accordance with international law or identifiable Ethiopia's sovereignty rights or to exercise jurisdiction that refers to other areas;
B) "a Contracting State" and "the other Contracting State", as required by the text, it means Turkey or Ethiopia;
C) the term "tax" of this Agreement in Article 2 refers to the understanding of any tax;
D) "Person" means any natural person includes any other body of persons formed a company;
E) "company", the term refers to any entity treated as a corporation or any organization in terms of taxation;
F) "national" means:
i) any individual possessing the nationality of a Contracting State;
Ii) any legal person deriving its status from the laws in force in a Contracting State, partnership or association expresses
;
G) "a Contracting State" and "other Contracting State" mean, respectively, a Contracting an enterprise carried on by the State a resident of the other Contracting State to a resident 'operated by means of an enterprise;
H) "competent authority" means:
i) in Turkey, the Minister of Finance or his authorized representative; and
ii) in Ethiopia, represents
the Minister of Finance or his authorized representative;
I) "International traffic" only, except when the ship or aircraft operations performed in the other Contracting State boundaries, effective management means any transport by a ship or aircraft operated by an enterprise located in a Contracting State.
2. By agreement of a Contracting State in respect of the implementation at any time, any term not defined therein shall, unless the context otherwise defined therein shall, for the purposes of the taxes to which the implementation of the Agreement, that date will have the meaning set forth in the State's legislation and in a sense is located in the tax legislation of that State, the other of the State the legislation will carry superior to the meaning given to that term. Article 4 RESIDENT


1. For the purposes of this Agreement, "a Contracting State to a resident" refers to that State, including any political subdivision or local authority, or in accordance with State regulations domicile, residence, place of management or of a similar nature under a tax liability due to any other criterion it means any person who. However, this term is only liable to tax in that State in income derived from sources in that State does not include any person.
2. When the provisions of paragraph 1 are therefore a real person either Contracting State the resident status of the person shall be determined as follows:
a) Such person shall be deemed a resident of the State in which a house can be permanent. If you have a house that people of both States also may be permanent, this is personal and will be treated as a resident of the State economic relations are closer (center of vital interests);
B) If the person's center of vital interests is contained by the State to determine, or both State of the person or a house can be permanent, he shall be deemed to State a resident of the house gained nearly remain;

C) If a person has acquired nearly remain in both home state or, if not such a home in both States concerned, this person shall be deemed a resident of the State of which he is a citizen;
D) if he is a citizen of both States or is not a citizen of both States, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3
. a person other than an individual is paragraph 1 shall therefore either Contracting State as residents, the competent authorities of the Contracting States to solve the problem by mutual agreement and determine whether the Agreement applies in what way this person. Article 5 1


OFFICE. For the purposes of this Agreement, "permanent establishment" means a fixed place of business is wholly or partly carried out the business of an enterprise.
2. "Permanent establishment" in particular encompass the following:
a) a place of management;
B) Branch;
C) The Bureau;
D) plant;
E) a workshop;
and f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; 3
. a period exceeding 12 months is an ongoing construction site, construction or installation project constitutes a permanent establishment.
4. This article Notwithstanding the preceding provisions of "permanent establishment" following of the term shall be deemed to include:
a) the maintenance of facilities, only the storage of the enterprise's goods or merchandise, used for the purpose of display or delivery;
B) only for storage of a stock of goods or merchandise belonging to enterprises, retention display or delivery;
C) a stock of goods or merchandise belonging to enterprises, solely for the purpose of processing by another enterprise;
D) a fixed place of work for only attempt to purchase goods or merchandise or held for collection of information;
E) a fixed place of work for which only preparatory or auxiliary character for the enterprise, held for the conduct of any other business;
F) for a fixed place of work, only (a) to (e) of retention for any combination of activities mentioned in subparagraphs but it is essential to have a preparatory or auxiliary character actions resulting from the execution of a combination of all of these activities in the fixed place of business.
5. 1 st and 2 nd connected with the provisions of paragraph Without being a person -6 th except in a Contracting State an agent of an independent status to whom the applicable paragraph, acts on behalf of an enterprise and has, and the name of the enterprise contract conclude agreements if it uses this authority usually, these people's activities case referred to in paragraph 4 and to work for a fixed place of business in accordance with the provisions of this paragraph, unless limited activities in nature that make this place work, these undertakings, in that State, in respect of any activities carried out to attempt the person has a permanent establishment will be accepted.

6. A Contracting State in the other Contracting State, a tipster ongoing business only in the ordinary course of their business, general commission agent or independent status walked through any other agency shall be deemed to have a permanent establishment in that other State. However, when it comes to agent activity of all or almost all a part of this attempt to devoted and composed in their commercial or financial relations between undertakings with agencies or created conditions when differ from those which would be made between independent enterprises, this person, independent status as an agent in the sense described in this paragraph It will not be accepted.
7. a company which is a Contracting State to a resident of the other Contracting States which resident or that other State carrying on business (whether through a permanent establishment or otherwise) controls the company or is controlled by it, each of the companies will create a permanent establishment of the other.

Article 6 INCOME FROM REAL ESTATE ASSETS OBTAINED
1. Income derived from immovable property situated in the other Contracting State a resident of a Contracting State (including income from agriculture or forestry) 'may be taxed in that other State.
2. "Immovable property", the term shall be defined according to the legislation of the Contracting State in which the assets. Terms in any case, property accessory to immovable property, agriculture (fish involved in the production or breeding) and tools used in agriculture and forestry, rights related to real estate property will be applied to private law, real estate usufruct rights and mineral deposits, sources and other natural resources at an operation or operating rights It shall include rights arising on fixed or variable payments; ships, boats and aircraft shall not be regarded as immovable property. 3
. The provisions of paragraph 1, the direct use of immovable property shall apply to income derived from the letting or use in any other form.
4. The provisions of paragraphs 1 and 3 paragraphs at the same time, an enterprise and self-employment activities and income earned from immovable property shall also apply to income derived from immovable property used for the performance. Article 7 BUSINESS PROFITS


1. To gain a Contracting State unless the enterprise carries on business through a permanent establishment unless there is in the other Contracting State shall be taxable only in that State. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in that other State only to be limited to the amount attributable to that permanent establishment.
2. Paragraph 3 Without prejudice to, if a Contracting State on business through a permanent establishment situated in the other Contracting State, each Contracting State in earnings will be attributed to that permanent establishment, this establishment located in the same or similar activities under the same or similar circumstances, a separate and independent If an attempt were to gain a completely independent character had been formed to attempt the work will get what earnings will be a gain of the same amount.
3
. In determining the profits of a permanent establishment in the State in which the permanent establishment is located or conducted elsewhere, the aim of the management and workplace, including general administrative costs shall be allowed as deductions expenses appropriate.
4. Commercial by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise with no profits shall be attributed.
5. Earnings receives the scope of income elements arranged separately in other Articles of this Agreement, the provisions of those Articles shall not be affected by the provisions of this Article. Article 8


SEA AND AIR TRANSPORT 1. earnings derived from operations of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise.
2. The board of the ship a shipping enterprise of effective management of this undertaking, the Contracting State in which the port where the vessel is registered, if there is such a port where the vessel is registered, shall be deemed to ships operating when the resident in the Contracting State of which he is a resident. 3
. For the purposes of this article, a Contracting State in international traffic of the enterprise of ships or profits accruing from aircraft operation will also include the gains obtained provisions of paragraph 1 of the acquisition as incidental to the profits to be applied to the use of containers with the condition or rented.
4. The provisions of paragraph 1 of this Article the same time, a partnership, a joint venture shall apply to an agency or the participation in the profit with international activities. Article 9 ASSOCIATED ENTERPRISES


1. a) a Contracting State participates directly or indirectly in the management of the other Contracting State, when he joined, control or capital, or
b) the same persons participate directly or indirectly in the management of a Contracting State in the other Contracting State, when added to the control or capital | the || and in both cases, that occur in commercial or financial relations between the two undertakings or created conditions when differ from those which would be made between independent enterprises, should be, but formed or created conditions gains show up in one of the undertakings because, it is included in the profits of that enterprise and accordingly taxable.
2. Where a Contracting State includes in the profits of an enterprise of taxation, profits on which of the other Contracting other State enterprises which are taxed in the State and earning at the same time grasp the first-mentioned State, taking into conditions consideration should be between the two enterprises later the first-mentioned State made the calculations in case of earnings determined as a result, State other appropriate adjustment to the amount of the tax on these profits it receives to determine if it considers that there will be over. This adjustment, other provisions of this Agreement shall be considered and shall consult the competent authorities of the Contracting States when required. Article 10 DIVIDENDS


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

2. However, such dividends may, at the same time the company paying the dividends is a resident and taxed in the Contracting State according to the laws of that State; However, if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 3
. This article used "dividends" means income from shares, the dividend shares or jouissance rights, founders not shares or the debt-claims, participating in profits derived from other rights income by distributing the company's resident that according to state regulations to income derived from taxation shares the same treatment who refers to income derived from other corporate rights.
4. The other Contracting State in a Contracting State company carrying on business through a permanent establishment situated therein, after having been taxed under Article 7, where the work on the remaining amount in the Contracting State 2 of this Article be taxed in accordance with paragraph.
5. the beneficial owner of the dividends is a Contracting State, with the event if the dividends paid by companies resident that carries on business through a fixed establishment in the other Contracting State or is found in self-employed activities through the other states located at a fixed location and of acquiring such dividends such permanent establishment or If there is a significant link between the place fixed, the provisions of paragraphs 1 and paragraph 2 shall apply. In this case, it will uygulanca provisions of Article 7 or Article 14, as the case. Article 11 INTEREST


1. Arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State.
2. However, such interest may also be taxed in the Contracting was obtained by the State and that State's legislation; but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3
. Notwithstanding the provisions of paragraph 2:
a) interest expense was born in Ethiopia and the Government of Turkey or the Republic of Turkey Central Bank shall be exempt from tax in Ethiopia;
B) the nature and the interest paid to the Government of Ethiopia or Ethiopian National Bank in Turkey shall be exempt from Turkish tax.
4. This article is used in the "interest" means, whether or not connected to the mortgage guarantee or borrower you know will recognize the right to participate in the profits, income arising from claims of every kind, and particularly refers to revenues derived from government securities, bonds or debentures.
5. the beneficial owner of the interest is a Contracting State, and if no commercial activity by the other Contracting State through a permanent establishment situated is obtained interest or is found in self-employed activities by the other State located at a fixed location and receive payment of such interest among such permanent establishment or fixed base effect If there is a tie, and paragraph 2 of Article 1 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.

6. A Contracting State itself, a political subdivision, the interest paid by a local authority or a resident of that State, shall be deemed to arise in that State. However, the person paying the interest, whether a Contracting State to a resident or not, has in a Contracting State interest is paid to lead to a permanent establishment in connection with which the indebtedness on or has a fixed base and such interest is borne by such permanent establishment or fixed base, then such interest, establishment or fixed the State in which it is located shall be deemed to arise.
7. The amount of interest paid in exchange for receivables from real beneficiaries payer or because of a special relationship with any other person with both, exceeds the amount which would have been agreed between the beneficiary and the payer in the absence of such a relationship, provisions of this Article shall apply only to the last-mentioned amount. In this case, the excess part of the payments, taking into consideration other provisions of this Agreement shall be taxable according to the laws of each Contracting State. Article 12 of


ROYALTIES 1. A Contracting State and arising in the other Contracting State royalties on royalties paid to a resident of the other Contracting State may be taxed.
2. However, these royalties are taxable in the Contracting State in which they arise and according to the laws of that State; However, if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. 3
. This article is used in "royalties" to the term, literary, including radio and television recordings and films, artistic or scientific of all kinds of copyright, of any patent, trade mark, design or model, plan, use of the secret formula or process, or or in exchange for the right to use industrial, commercial or scientific experience-based knowledge refers to any payment in return.
4. the beneficial owner of the royalties is a Contracting State, if carries on business through a situated in the other Contracting State in which he obtained such price workplace or is found in self-employed activities by that other State situated at a fixed location and workplace rights or assets that paid such price or is effectively a link between fixed locations, paragraphs 1 and paragraph 2 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.
5. A State itself, a political subdivision, a local authority or of the royalties paid by a resident of that State, shall be deemed to arise in that State. However, paying the royalties person, you get a Contracting State to a resident or not, when a Contracting State royalties if it is connected with a permanent establishment or fixed base in connection with which liability reasons payments and royalties are borne by such permanent establishment or fixed base, such royalties the cost of in the State in which the permanent establishment or fixed base shall be deemed to arise.

6. Use the amount of right or information for royalties paid in exchange for royalties, between the beneficial owner and the payer or the reason of a special relationship with any other person with both, if the payer in the absence of such a relationship exceeds the amount to be agreed between the real beneficiaries of these provisions are only the most It shall apply to the last-mentioned amount. In this case, the excess part of the payments, taking into consideration other provisions of this Agreement shall be taxable according to the laws of each Contracting State. Article 13 CAPITAL GAINS


1. Mukîmîne of a Contracting State, situated in the other Contracting State, and Article 6 of the gains derived from the alienation of immovable property referred to, may be taxed in that other State.
2. A Contracting State of the disposal of a fixed place of immobile assets that other Contracting State owned a business, including commercial presence marketable assets or a Contracting State a resident of the other Contracting State uses in order to perform an independent professional activity Gains, this establishment (alone or with the whole enterprise together ) or including gains from the disposal of fixed base, may be taxed in that other State. 3
. Ships or aircraft operated in international traffic or such ships or supplied from the alienation of movable property pertaining to the operation of the aircraft gains will be taxed only enterprise of a Contracting State in place of effective management is located.
4. 1, 2 and 3 in paragraphs gains derived from the alienation of any property other than those specified, shall be taxable only in the Contracting State of which he is a resident of the disposal of.
5. 1, 2 and paragraph 4 provisions of either Contracting State to a resident of the other State, the first-mentioned State a resident of the bonds issued by and gains by the disposal of shares if the acquisition and does not exceed a period of divestitures year, the right of taxation according to the laws It will not affect. Article 14 Independent Personal Services


1. revenue generated by a Contracting State a resident of professional services or from his other activities of an independent character, that person shall be taxable only in that State unless it has a fixed place will be able to perform continuously activities in the other Contracting State. People's income when it has such a fixed base, may be taxed in that other State only to be limited to the amount attributable to that fixed it said.
2. "Professional services" includes especially independent scientific, literary, artistic, educational or teaching activities, as well as the doctors, lawyers, engineers, architects, dentists and the independent activities of accountants. Article 15 INCOME FROM EMPLOYMENT


1. 16, 18, 19, 20 and without prejudice to the provisions of Article 21, a service therefore wages earned in a Contracting State a resident of wages and other similar remuneration, that unless the employment is exercised in the other Contracting State shall be taxable only in that State. If the services are rendered in that other State may be taxed in that other State revenues derived therefrom.

2. 1 Notwithstanding the provisions of paragraph, a Contracting State a resident of the income derived by a service exercised in the other Contracting State if:
a) persons who generate revenue, the other States in the beginning of the calendar year or ends in any twelve-month period a or if not to exceed a total of 183 days on several occasions, and
b) Payment, if the other State resident by a non-employers or on behalf of an employer, and
c) payment of a permanent establishment which the employer has in the other State or a fixed base
not due shall be taxable only in the first-mentioned State. 3
. This article Notwithstanding the preceding provisions, obtained in respect of an employment exercised a ship or aircraft operated in international traffic salaries, wages and other similar remuneration, enterprise and place of effective management taxed in the Contracting State in which he found.
Article 16 PAYMENTS MADE BY A
MANAGER
of a Contracting State a resident of the other Contracting State is a resident of a company's board of directors to be members thus achieved fees and other similar payments, that other State may be taxed. Article 17 ARTISTS AND SPORTSMEN


1. 14 and notwithstanding the provisions of Article 15, a Contracting State with theater, cinema, radio or television artist, an artist as a musician or an athlete in the other Contracting State exercised that come from his personal activities, that other State may be taxed.
2. An artist or income in respect of personal activities as athletes exercised not to the entertainer or sportsman himself but to another person, that income 7, 14 and bound by the provisions of Article 15 notwithstanding the artist or taxed in the Contracting State in which the performance of the athlete's activities. 3
. income derived from operations by an entertainer or sportsman in a Contracting State exercised, this visit is concerned with the state fully or substantially the other Contracting State, if it met from public funds of a political subdivision or a local authority shall be exempt from tax in that State. Article 18 PENSIONS


1. Article 19 is without prejudice to the provisions of paragraph 2, a pensions and other similar remuneration paid in consideration of past employment to a resident of the Contracting State shall be taxable only in that State. These provisions also apply to a resident of a Contracting State also provided regular payments for life.
2. other permanent or incidental to compensate the suffered personal losses with pensions paid by a Contracting State or one of its political subdivisions and regular salary payments provided lifetime payments shall be taxable only in that State. 3
. The term "annuity" means, depending on the full and sufficient payment on the obligation for a measurable benefit with money, or money, for life or a specific or determinable period of time, at certain times, regularly paid represents the total amount. Article 19 PUBLIC SERVICE


1. a) A Contracting State itself, a political subdivision or in respect of services rendered by an individual to the local authority of that State or subdivision or made by the administration and the remaining charges except pensions, wages and other similar remuneration shall be taxable only in that State.

B) However, where services are rendered in the other Contracting State and the individual is a resident of that State, such salaries, wages and other similar remuneration shall be taxable only in that other State. But this person:
i) is a national of that State; or
ii) only did not become a resident of that State to perform this service is compulsory
.
2. a) A Contracting State itself, a political subdivision or a local authority or by that State thereof to created fund, subdivision or authority to do service pensions paid to a real person in return shall be taxable only in that State.
b) However, if the natural person is a resident of the other Contracting State, and citizens, such pension shall be taxable only in that other Contracting State. 3
. A Contracting State itself, a political subdivision or a local authority in return for services rendered in connection with a business carried on by salaries, wages and other similar remuneration and pensions of 15, 16, 17 and the provisions of Article 18 shall apply. Article 20 Students and trainees are


1. Contracting During his visit to the state that other Contracting State to a resident or just before the first-mentioned State solely for education or a student or apprentice who is the purpose of vocational training, livelihood, payments made by persons residing outside the first-mentioned State for education or training expenses, first mentioned state shall be exempt from tax.
2. During a visit to the Contracting State or that just before the other Contracting State to a resident of the first-mentioned State in the study or to obtain practical experience related to the formation, not exceeding one year or while in charge gained by a student or trainee who perform services will not be taxed in the first-mentioned State.
Article 21
TEACHERS
a Contracting State, a university in this state, high school, college or other recognized educational institution in order to make teaching or research visit for a period not exceeding two years, and during this visit or just before the other Contracting State to a professor or teacher, a resident, said teaching or as a result of their research, the income is taxable in the other Contracting State shall be exempt from tax in the first-mentioned State with the condition to obtain from sources other than the state of said first of the said income. Article 22 OTHER INCOME


1. Resident of a Contracting State, where you were born is born, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
2. Article 6 of the 2 nd, except for income derived from immovable property as defined in paragraph, a Contracting State which said the recipient of such income, on business through a permanent establishment situated in the other Contracting State or is found in self-employed activities by that other State situated at a fixed location and the revenue is paid to the rights or property of such permanent establishment or fixed base in place an effective bond, it means the provisions of paragraph 1 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.

PREVENTION OF DOUBLE TAXATION Article 23

1. A Contracting State when the provisions of this Agreement in accordance with achieved an income that can be taxed in the other Contracting State, the first-mentioned State, the resident from the tax on the income, will be allowed to deduct an amount equal to the tax paid on income in that other State.
However, such deduction, which is attributable to taxable income in the other State shall not exceed the amount of tax on the income computed before the deduction.
2. For the purposes of this Article, paragraph 1, a Contracting State, the tax on nature for commercial gain, under the legislation of that State, is subject to reductions or exemptions for a limited time, the said tax, Article 7 of the said real person of the commercial gain of 35%, the company trade If the gain shall be deemed paid in the amount not to exceed 30%. This provision shall apply only for the next 10 years from the date of entry into force of the Agreement. 3
. in accordance with the provisions of the Agreement, if the income earned by a resident of a Contracting State are exempt from tax in that State, that State, such resident, in calculating the tax on the remaining income, take into account the exempted income. Article 24 1


JUNCTION MINATION. Of a Contracting State citizens of the other Contracting State, that other State of its citizens under the same conditions, especially in terms of residency, any taxation can stay or they face and different from the related liability or a heavier taxation or will be subject to the associated liability.
2. Article 10 of paragraph 4 of the provisions for an establishment which has in the other Contracting State of a Contracting State, the other States, according to the other State undertakings carrying on the same activities will be faced with less favorable taxation. 3
. A Contracting State by the other Contracting State one or more residents, directly or indirectly, totally or partially owned capital or capital controlled enterprises, in the first-mentioned State to any taxation they are or may be subject to other similar enterprises of the State and or different from the related liability they will be subject to heavier taxation or the related liability.
4. These provisions have its own resident of a Contracting State personal allowances due to personal or family circumstances apply, the tax base and discounts will not be understood in terms that you have to apply it to the resident of the other Contracting State. Article 25 Mutual Agreement Procedure


1. A Contracting State, when it reached the conclusion Contracting State where one or both of the transactions he is to make a tax of not conforming to the provisions of this Agreement or will this state of the remedies provided by the domestic legislation to, the Contracting that event, a resident of the State competent authority or status Article 24 1 If you fall to the appropriate paragraph, a citizen of that Contracting State is the competent authority. The case, from the first notification of the action resulting in taxation contrary to the provisions of this Agreement shall be made within three years.

2. These finds itself justified and challenged the authorities can not reach a satisfactory solution is, in order to prevent a taxation contrary to the agreement, will endeavor to mutual agreement with the competent authority of the other Contracting State. 3
. The competent authorities of the Contracting States, any difficulties or doubts arising as to the interpretation or application of this Agreement shall endeavor to resolve by mutual agreement. The authorities at the same time, resulting in cases not provided for in the Agreement may also consult together for the elimination of double taxation.
4. The competent authorities of the Contracting States to reach agreement on the issues specified in the preceding paragraph may communicate with each other directly or through a joint commission consisting of themselves or their representatives. Article 26 INFORMATION EXCHANGE


1. The competent authorities of the Contracting States, as long as the mismatch with the knowledge or agreement necessary for the execution of this Agreement, the information will hold subject to changes that are necessary for the implementation of domestic legislation on taxes covered by the Agreement. Any information received by a Contracting State, that State of the information obtained under the domestic legislation will be kept confidential and as such, but only with the assessment or collection or enforcement or punishment of the tax specified in this Agreement and deal with complaints in these matters and appeals officers persons or authorities (judicial authorities and including administrative bodies) can be given. Such persons or authorities shall use such information only for such purposes. These persons or authorities may disclose the information in public court proceedings or in judicial decisions.
2. The provisions of paragraph 1, in no way a Contracting State:
a) to carry out administrative measures at variance with that or the other Contracting State legislation and administrative practice;
B) to supply information which is not obtainable under the laws or that or the other Contracting State the normal administrative procedures;
C) Any commercial, industrial, or professional secret or trade process, which makes public information or publicity not falling contrary to public order
obligation can not be interpreted to be put under. Article 27


diplomatic agents and consular officers
provisions of this Agreement, the officers in the diplomatic or under the general rules of international law or the provisions of special agreements will affect the fiscal privileges of consular officers. Article 28 ENTRY INTO FORCE


1. Each of the Contracting State of the completion of the procedures required by its law for the entry into force of this Agreement shall notify the other Contracting State. This Agreement shall enter into force on the date of the later of these notifications.
2. The provisions of this Agreement:
a) in respect of taxes withheld at source, the first day of January next following the date on which the Agreement enters into force later or paid or owed amounts; and
b) in respect of other taxes, the first day of January next following the date on which the Agreement enters into force or later will apply to taxable years beginning
.

Article 29 Termination

1. This Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Agreement by giving notice of termination through diplomatic channels at least six months before the end of any calendar year after a period of five years from the date the Agreement enters into force. In this case the Agreement:
a) in respect of taxes withheld at source, for amounts paid or credited after the end of the calendar year in which the notice is given; and
b) in respect of other taxes, after the end of the calendar year in which the notice is given to taxable years beginning
will express provisions.
ISSUES THIS CONFIRMS that, whereof the undersigned, duly authorized, have signed this Agreement.
In the English language, on March 2, 2005 it was organized in Addis Ababa.
FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA
GOVERNMENT OF THE GOVERNMENT OF THE REPUBLIC
(Signature) (Signature)
PROTOCOL
Republic of Turkey and the Ethiopian Federal Democratic Republic between the Government on Income Tax signed the Double Taxation Avoidance Agreement duly authorized representatives, have agreed to be an integral part of the Agreement, the following provisions.
1. 7th Additional Article:
Article 7 1 in terms of paragraph a work made by means of goods or merchandise of the same sales or the like, the same as those carried out after, or other commercial activities or derived from similar enforcement of earnings, this process, to avoid taxation in the State in which the permanent establishment is located in order to prove that if carried out, is attributable to that permanent establishment.
2. In addition to the provisions of Article 10:
"Dividends" of the term, investment funds and Turkey in terms of revenue derived from investment trusts are also understood to include matters.
ISSUES THIS CONFIRMS that, whereof the undersigned, duly authorized, have signed this Protocol.
In the English language, on March 2, 2005 it was organized in Addis Ababa.

FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA
GOVERNMENT OF THE GOVERNMENT OF THE REPUBLIC
(Signature) (Signature)