Turkish Grand National Assembly Warning: You Are Viewing Act, The Parliamentary General Assembly Has Already Adopted. If It Does Not Include The Changes Made Later. The Government Of The Federal Republic Of Ethiopia D

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

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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.


 

REPUBLIC OF TURKEY GOVERNMENT TO ETHIOPIA FEDERAL IT IS THE LAW TO PREVENT THE DECISION TO PREVENT THE DECISION AND THE APPROVAL OF THE OCTOBER PROTOCOL IN ACCORDANCE WITH THE REPUBLIC ' S GOVERNMENT.

 

Kanun # 5599

 

Acceptable Date: 13/3/2007      

 

MADDE 1- signed on 2 March 2005 in Addis Ababa "The Protocol" to Prevent Double Taxation in Taxes and "Protocol" by the Government of the Republic of Turkey and the Government of the Federal Democratic Republic of Ethiopia to Prevent the "Protocol" is available.

ARTICLE 2- This is the date on the release date of the Law.

TICAD 3- The Council of Ministers executes the provisions of this Law.

 

 

 

 

 

 

 

PROCESS THE REPUBLIC OF TURKEY GOVERNMENT

ETHIOPIA ' S FEDERAL REPUBLIC OF FEDERAL DEMOCRATIC GOVERNMENT

IN RECEIVED DATA FROM THE ARRIVAL

ANTI-TAX-AVOIDANCE UNDERSTANDING

 

REPUBLIC OF TURKEY GOVERNMENT

AND

FEDERAL DEMOCRAT FOR ETHIOPIA

REPUBLIC GOVERNMENT

 

In order to make a statement that prevents double taxation on taxes received through Revenue

UNDERSTAND OTHER THAN

Clause 1

CAPACITY COVERED

This means that it will be applied to the people who are the people of one or both of the States.

Article 2

KAVRANAN VERGALS

1. This will apply to taxes on income from the State or political subdivisions, or by neighborhood administrations, regardless of how much of this is understood.

2. Taxes levied on earnings that are imposed from the transfer of real estate or real estate, including taxes on the total amount paid by the people, or the total amount of the salary (s), all taxes received over the total income or income items will be considered as taxes received from the income.

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

a) in Turkey:

i) income tax

ii) corporate tax;

iii) the share of funds received over income tax and corporate tax;

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

b) in Ethiopia:

i) tax on revenue generated from service and fee charges;

ii) received revenue from agricultural activities through real estate rental revenues. tax, including taxes, and tax on revenues from non-public and non-legal entities;

iii) taxes on revenues from services that are performed in the dormitory;

iv) dividend, informal merit, and tax due to a number of votes;

v) higher earnings tax.

(This will refer to as "Ethiopian tax");

4. At the same time, the statement also included taxes that were identical to or substantially similar to existing taxes after the date of signing of the statement. will be applied. The competent authorities of the Aşit States will report to each other the important depositions made in the relevant tax legislation.

Clause 3

GENERAL DEFINITIONS

1. From the purposes of this task, unless the text is predicted to the contrary:

a) i) the term "Turkey", including its territorial waters and the air in which it is located The territory of sovereignty is used to protect, operate and protect legal resources in accordance with international law, or areas of sovereignty used by the rights of sovereignty, the sovereignty area of statements;

ii) The term "Ethiopia" refers to the Federal Democratic Republic of Ethiopia and the country in a way statements that use the authority or jurisdiction of Ethiopia, which is designated or designated in accordance with national territory and international law, is used;

b) The terms "A State" and "Secretary of State", according to the text of the text, Turkey or Ethiopia meaning;

c) The term "tax" comes to any tax in part 2 of this Statement;

d) any installation of "Kishi", a real person, a company, and any other installation. includes;

e) the term "February", any agency or any other entity that is acting as an institution in any other way of taxation. refers to a setup;

f) The term "Citizen":

i) any real person who is a citizen of a Âkit State;

ii) any legal entity that has gained status according to the legislation in effect in a Akitel State, Partner or association

refers to;

g) "The contact of the State of a Kite State" and the terms of the "monopoly State of the World", a Âkit A service that is being pushed out by the party of the state, and a service that has been pushed out by the machine of the Dianer's Devlet;

h) "Authority for authority":

i) in Turkey, the Ministry of Finance or its authorized representative; and

ii) in Ethiopia, the Minister of Finance or its authorized representative

refers to;

i) The term "internationalized traffic" is only being actualized within the state of the Realm State. The effective management refers to any application made by the ship or aircraft, except for the construction of a ship or aircraft, that is located by a network located in a Skit Devlette.

2. The implementation of a statement on any date by the State of the State is that any term, unless otherwise defined, is intended for the purposes of tax purposes. from the maintenance of this state in the current tax legislation, the meaning of this term is superior to the meaning given to this term in the state. It will be.

Clause 4

MUKOM

1. For the purposes of this statement, " a The term "the term of the State of Love" means that the State, including any political subsection or neighborhood administration, has any other means of residence, residence, administration or similar structure. income from the taxpayer due to a criterion. However, this term does not include any money that is being subject to tax in that state, only because of the revenue from sources 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:

A) Accept the inheritance of a state where only a permanent home is located. in the future If there is a home that will remain permanent in both Devlette, it will be regarded as the part of the state of the state, where their personal and economic relations are more closely related (vital interests). central);

b) If the state of the center of the vital interests of the Eucer is not determined, or If there is no permanent residence in both Devlette, it will be accepted by the state of the state where the home is located only when it has been left to remain;

c) If there is a home in both Devallette, or both Devlette, both Devlette if a home is said, this will only be accepted by the state of the state in which it is a citizen;

d) If both of the State's citizens are citizens or both of the State's citizens are not citizens, The authorities will resolve the issue in order to understand the problem.

3. A part of the real winter, when the 1st of the 1st frikra provisions, both in the State of the Azoys, were the most important. The competent authorities of the State States will resolve the issue of the problem and determine how it will be applied to this part.

Clause 5

ISRAELTagPreserver,b,180,184

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:

TagPreserver,p,0,138a) Management location;

b) Feb;

c) Bureau;

d) Factory;

e) Atele; and

f) Other than mine, oil or natural gas wells, overflow, or natural resources have been grapefied. any location;

3. A process of construction, construction, or installation is going to be a place for a period of 12 months.

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

a) The facilities of the company, the property of the business, or the commercial property of the company storage, purpose, or delivery purposes;

b) Only storage, private, or delivery purposes of a business or commercial property belonging to a business retention;

c) If a business or commercial property belonging to a contact is only available for a visit to a country the purpose of this;

d) Import or information of a fixed location only if a fixed site is a business or commercial the purpose of collection;

e) only prepared or helpful characters for the operation of a fixed location. the purpose of execution of any other person;

f) The activities discussed in a fixed location, only (a) to (e). the retention of a few; however, the activity is not prepared or helpful as a result of the execution of all of these activities at the fixed site. It will increase.

5. One of the provisions of the 1st and 2nd feats, a team of people acting in the name of a suicide, moves to the name of a suspect in a state of emergency -- a business that is likely to be implemented by a team of 6-6. If mukaandle is authorized to use this authority from the mutaden, the activities of this winter shall be based upon the provisions of this fikra, as specified in the 4th piece and are not made from a fixed location. This is the government, this is Devlette, in any activity that this person has been able to make for the United States. It will be considered to have a location.

6. In the event of a Fierce State, a State of the Union, the general commission is an ongoing trader, general commission agency, or any agency that has status on the status quo, only to its own. for execution, the owner will not be accepted as an owner in this state. However, a close or near completion of the activities of the agency is due to this visit, and commercial or financial relations between the network and the agency are in place, or This is not considered as an agency in the sense that is specified in this regard, as the conditions that are being made are different from the conditions that are required to be in the search of the community of people.

7. A company that is a member of the State of a âite, controls a company that is the member of the state, or in a commercial activity (in a workplace or other way) in the other State of the State of America, or its If it is controlled by, each one of the companies will not have an office space for the other.

Clause 6

RESULTING FROM GAYRISECURITIES

1. The income from real estate in the country of the Republic of Akiel (including income from agriculture or forestry) is taxed in this other State of the State.

2. The term "real estate" will be defined according to the legislation of the entity in which it is located. The term is, in any case, the assets and animals used in real estate, agriculture (including balm production or ability), and livestock, the provisions of special law provisions. real estate property rights, real estate inaction rights, and mining, resources, and other resources, whether sources and other sources of real estate are fixed or fixed. will cover the rights on payments; ships, vapurs, and planes will not be considered property assets.

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. In the case of commercial activity by a Minister of State for a Profitable State, it will be taxed only in this state, as it is not in commercial activity with a location in the Realm Of Akitur. If commercial activity is found in the above mentioned business, the profits of the country may be taxed in this other state, with only the amount of money that can be attributed to the business.

2. In the event of commercial activity by a member of the State for the Republic of Turkey in the Republic of Azit, to remain a resident of the 3rd fikra's provisions, both Sükit Devlette will be attributed to the loss of the What profit would be if there were a number of different and similar activities under the same or similar conditions, such as a separate and non-view, and completely unqualified property from the person who was involved in the workplace. It would be a similar amount of gain.

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 gain will be attributed to the office of this location only if it has been purchased for goods or trading on behalf of the United States.

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 AND AIR OVERFLOW

1. Profits from the carrier or aircraft carrier will be taxed only in the Akikit Devlette, where the effective management site is located in the international traffic.

2. If the effective management central ship of a shipping crew is on board, it is the port where the ship has been registered, or the ship's boat, if there is no port, where the ship has been lost. In the event that the person is the name of the company, it will be considered to be in place in the State.

3. For the purposes of this matter, the gains of a Profitable State government from the shipping of ships or aircraft in international traffic are reflected in the gains imposed by the 1st fikra provisions. It will also cover the gains from the use or lease of containers with the retention of the product as a result.

4. The provisions of the 1st phase of this Article will also be applied to the proceeds of a partnership, a partner, or an agency that operates the international community.

Article 9

SUPPORTED CONTACT

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

b) A State of the Union and the other in the case of a State of the Union, indirectly, or indirectly. the management, control, or capital of the community,

and both, both commercial or financial services between the two buses, or the conditions that are being generated, the gain that is not showing itself in one of the people due to the conditions in which the people should be looking for, but due to the conditions in which they should be among the people who need to be in the future. It is added to the earnings of the community and can be taxed accordingly.

2. It is the first mentioned state of the state to include the benefit of the country's own taxation, which is taxed in the earnings of the State of the State and the tax on which it will be taxed, and the first of which is the first ever mentioned. The win would be the result of the fact that the conditions between the two teas were kept in front of the state, and then the first mentioned state of the calculations was not the result of the profit. if it determines that it is in place of the specification, it will make the necessary corrections to the amount of tax that is received over the benefit. 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 payment of the dividend, in the case of the Devlet Devlette and the legislation of this state; however, the true beneficiary of the dividend is the true beneficiary. In this way, the tax will not increase 10 per cent of the gross dividend amount to be received in this way.

3. The term "dividend", used in this material, is the other to bear in terms of stocks, intifas, or intifa rights, constituent stocks or non-profits. From the state of the state, where the company is treated with revenues from rights, the company has the same treatment as income from taxation in accordance with the legislation of the state. refers to revenue.

4. The winner of a commercial activity in commercial activity with an office in the Diyer Akit Devlette, after being taxed according to the 7th Amendment, found its place over the remaining part of the city. In the state, it can be taxed in accordance with the 2 nci feats of this material.

5. The true beneficiary of the dividend, a Sovereign State team, is found in commercial activity with a fixed site of the company that pays the dividend, or is located in the state of the country. If a fixed location is found in free professional activity and a significant number of people are in line with this business or fixed place, the 1st and 2nd fikra provisions are found. It will not be applied. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

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 also be taxed according to the Minister of Atkit and the State of the State; however, the real beneficiary of the interest is the tax, the interest of the State of the State, in this way. It will not waste 10 percent of your gross amount.

3. 2 see the ncr provisions:

a) paid to the Government of Turkey and the Government of the Republic of Turkey, or the Central Bank of Turkey The interest will be exempted from the Ethiopian tax;

b) interest paid to the Government of Ethiopia and the Government of Ethiopia or the National Bank of Ethiopia It will be exempted from the tax.

4. The term "interest", used in this material, is a matter of interest to the mortgage guarantee or recognition of the debtor, all sorts of creditless revenue, and especially public securities. statements that are obtained from bonds or debt bonds.

5. The true beneficiary of the interest in a Kite State team is if commercial activity is found in a workplace in the country where interest is obtained, or a fixed place in the other state. if they are found in free professional activity and the interest in question is to be paid, the provisions of the 1st and 2nd fikra shall not be applied if there is an active view in this place or fixed place. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

6. A State of the State itself, a political subsection, a neighborhood administration, or the interest paid by a member of this State, will be accepted in that state. However, the interest-paying person, whether it is a member of a Kite State or not, has a fixed place, or has a fixed place, with the debt-to-credit relationship that has caused an interest payment in a Âkit State. If the interest is found at this location or fixed place, it will be considered to be obtained in the State where the location or the location of the subject is located.

7. The amount of interest paid in the credit is due to the fact that there is no such relationship, because of the actual beneficiary between the payable or both, or both, and the beneficiary in cases where such a relationship is not. 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 of the Azoys, under consideration of the other provisions of this statement.

Article 12

COST-OUT-OF-RIGHTS

1. The amount of diligent rights, which is paid to a member of a Kite State, and a member of the other in the Devlet State, may be taxed in this other State.

2. However, the cost of monetary rights may be taxed according to the legislation of the Atkit and the State of the State; however, the real beneficiary of the cost of the property is the real beneficiary of the Government of the State. The amount of the tax is not 10% of the cost of the tax gayrimaterial.

3. The term "Gayrimaterial rights," which is used in this material, is a form of literary, artistic or scientific copyright, including radio and television records, as well as a patent on any kind of patent. The use of the mouse, pattern, or model, plan, secret formula or production method, or the use of the production method, or the accumulation of information on the water, commercial or scientific experience. Refers you to any payment.

4. The true beneficiary of the cost of an Akit State is a real beneficiary, if it is found in commercial activity, or in this other State of the Union, in which the price of an area of the other in which the price is obtained. If the area is found in a fixed location with a fixed site and the right to be paid or there is an active view of this office or fixed site, 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.

5. A State itself, a political subdivision, a neighborhood administration, or the price of diligent rights paid by a member of this State, will be accepted in that state. However, the person who paid the non-diligent right is either a member of a Grievance Device or not, with the obligation to pay the price of an invigorate charge in a Fallen State. The value of the property or fixed place is obtained in the State of the country or fixed place, as it has the place and the cost of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of 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 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. In order to conduct free trade activities in the Turkish state, including the commercial presence of a company owned by the Minister of State, in the commercial entity of the company, or in the case of the State of the Azox. 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. Proceeds from disposal of securities related to the ship or aircraft or aircraft being pushed out in international traffic are only effective at the time of the active. It will be taxed in the Akit Devlette, where the management location is located.

4. 1, 2, and 3% gains from the disposal of the remaining assets of the United States, will be taxed only in the Fuel State, which is the only person who has been left out of the world.

5. 1, 2 and 4, the provisions of one of the countries in the Republic of Turkey have sold bonds and shares issued by a member of the other State, which was first mentioned by a member of the state. gains will not affect the right to taxation according to its legislation if it does not take a year off between power and hand.

Article 14

FREE TRADE INTEREST

1. In the event that a Turkish State team has obtained free vocational services or other activities, it has been able to carry out its activities continuously in the event of the other, in the event of a Turkish in the country. Only this state will be taxed if it doesn't have a fixed place. If the person does not have such a fixed place, the revenue can be taxed in this other State, only to be left with the amount that can be attributed to that fixed place.

2. The term "free vocational services", especially scientific, literary, artistic, educational or other activities carried out as a part of us, is a response to the fact that physicians, lawyers, engineers, architects, It covers the activities of the workers and accountants.

Article 15

PRINTED INTEREST

1. The provisions of the Articles 16, 18, 19, 20, and 21 are to be saved, the amount of which a State team has obtained through a service, the salary, the salary and the other, unless the service is performed in the State of the Republic of Turkey. It will only be taxed on this state. 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:

a) Revenue resulting in any country that is either starting or ending in the related calendar year. if a total of 183 days at a twelve-month period not to have a total of 183 days, and

b) Payment is an informal or non-conserving name of the other State. If it is done, and

c) Payment is from a place or fixed place that the owner has in the other State is not caused

will be taxed only on the first mentioned Devlette.

3. The compensation of a ship or a service that was executed in international traffic, or the fee obtained by a service that was executed on the aircraft, is the current and the other, the compensation of the nation's previous provisions. It is taxed in the Akit Devlette, where the management place is located.

Clause 16

PAYMENTS TO MANAGERS

A member of the State team is a member of the board of a company that is the member of the other ÂKit State Fee-like payments, and other similar payments, can be taxed in this other State.

Article 17

ARTIST AND ATHLETES

1. An artist, a musician, or an athlete, performing in the art of 14 and 15 articles, is an artist, a musician, or an artist, and an artist. They come from the current activities, they can be taxed on this other State.

2. The income from an artist or sportsman's executive actions is that if the artist or the athlete himself is directed to a position, the income is seven, 14, and 15, with the provisions of the 14th. It is taxed in the Akit Devlette, where the activities of the artist or athlete are performed.

3. An artist or athlete's income from activities performed in a Kite State, the state of which the state of the State of the United States, in which a political subsection is or is not a part of the visit to the State, is a state of its kind. In the event that a neighborhood administration is involved in public funds, this state will be the exception to the tax.

Article 18

RETIREES

1. The pensions and other similar revenues paid for by the passage of a US State team to the 2 nci provisions of the 19th Amendment are withheld, but only in this State. will be taxed In addition, this provision will also apply to regular payments for a lifetime of the Government of the Azoth.

2. To compensate for the harmful damages, the pensions paid by one of the State or political subdivisions, and regular payments for life, are left or are not. payments will be taxed only in this Devlette.

3. The term "regular payment" is a lifetime or a certain amount of time, depending on the obligation of money or money to be paid full and sufficient payment in a measure of measurable interest. at times, it represents the total amount to be paid regularly.

Article 19

PUBLIC SERVICE

1. a) A Public Service, subsection or administration of the State, subdivision or administration of a Kite State, a political subdivision, or a neighborhood administration. The remaining fee, salary, and other such payments will be taxed only in this State.

b) However, when the service is performed in the Devlette Circuit and the real person is a part of that State The fee, salary, and other such payments will be taxed only in this other State. However, this is:

i) being a citizen of this State; or

ii) not only did this state transition to a status of this service to be performed by this service

is required.

2. a) A State of America itself, a political subdivision, or a local government, or funds generated by such funds, to a real person in the service of this state, subsection or administration. paid pensioners will be taxed in this state only.

 b), however, if the real person is a member of the State and a citizen of the State, The pension will only be taxed in this other-in-the-place, Azit Devlette.

3. A Department of State itself, a political subdivision, or a neighborhood administration, is retiring with commercial activities, including fees, salary, and other similar payments. The provisions of the items 15, 16, 17, and 18 will apply to the members of the community.

Article 20

OTHERS AND INTERNS

1. In a visit to the State of Love, or just before, I am a teacher or an intern who is the first to speak of the State of Love, or to an intern or an intern who has only the purpose of my life or professional education. Payments made by people residing in the State of State, which is originally mentioned for the costs of living or professional education, will be the exception of the first mentioned Devlette.

2. One year to win an application for the first ever mentioned Devlette death or formation of the first ever mentioned State of the World visit to the State of Akili visit. The charges obtained by an intern or intern who are in service during any period of time or time, will not be taxed in the first mentioned Devlette.

Article 21

TEACHERS

A State of the Union, a university, high school, school or other accepted education in this state a professor or teacher who visited for a period of not two years in an institution that did not have two years to do or to conduct research, or immediately before or immediately preceding this visit, is a professor or teacher of the other. Revenues or revenues are subject to tax revenue, which is subject to tax revenue. The first mentioned State of the State will be the exception of the data from the first mention of the State.

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 from real estate assets described in the 2-nci fund of the 6-cent clause, the beneficiary of the said income of a Profit State team is the beneficiary of an office space in the other Profit State. if a fixed place in commercial activity or a fixed place in this other Devlette is found in free professional activity, and the income is paid, or there is an active place between this office or fixed site. The provisions of this income will not be applied to the 1st fikra provisions. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

Article 23

PREVENT TAX VERITABLE

1. In accordance with the provisions of this Judgment, in accordance with the provisions of the Sovereign Income State, the first mentioned State, the tax that hit the income of this candle, in the other State of the Union. the amount of tax that is paid over the revenue will allow you to have the same amount of tax.

However, the subject matter can be attributed to taxable income in the other Devlette the amount of tax received over the calculated revenue before the mag will not be expected.

2. For the purposes of the 1st of this Article, the tax on commercial gain in a Profitable State, in which this State is subject to legislation, is reduced for a period of time, subject to an exception. The tax will be deemed to have paid 35% of the commercial earnings of actual people mentioned in the 7 nci clause and 30% of the companies ' commercial earnings will not be paid in the amount. These fikra provisions will only be applied for a period of 10 years after the current date of the follow-up.

3. In accordance with the provisions of the Government, if the income obtained by a Convenience Government is exempted from this State, this State will be exempt from calculating the income of the remaining income of this person. income can also be considered.

Article 24

SEPARATION OF SEPARATION

1. The citizens of a State Government, in the other part of the State, are not able to tax and pay for their citizens, especially in the direction of the state, in the direction of the country, especially in the direction of the state, in the direction of the state. They will not be subject to a tax or a greater amount of taxation or other liability for any of the people.

2. In order to hide the provisions of the 4th section of the 10th Amendment, an area of the State's foreign policy, in the other State of the Republic of Turkey, has the same activities as the other State, which conducts the same activities in the other state. Fewer lehe will not be involved in a taxation than their contact.

3. The first mention of a State of the World, the government of one or several of the countries in which the government, or its direct capital, or its capital, is controlled by one or several parties, or whose capital is controlled. In the state, they are subject to the taxation of this state, or that they may be subject to the taxes or other taxation that they may or may not otherwise be subject to. They will not be held.

4. These provisions will also have to apply the discounts, taxes and matrah discounts to the State of the Akiti State, which is used by a State of the State to their own party or in a family of families. It will not be understood.

Article 25

BUSINESS MANAGEMENT PROCEDURE

1. This is the case where a State of the State has failed to create or create a tax on the provisions of one or both of them, in an unrued taxation of the provisions of the State. The citizen's authority or the state of the United States, in accordance with the state's authority or the 1st of the 24th article, is expected to comply with the civil regulations stipulate in the civil regulations of the states. He could supply the government to the state's authority. During the first declaration of the act, which resulted in a taxation violation of the provisions of the Statement, the following will be done within three years.

2. He 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 state's authority. It will make an effort.

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 authorities of the United States have a commission, either themselves or their representatives, to reach a deal in order to deal with the issues outlined in the previous fats. They can communicate with it.

Article 26

BASED on DECIMAL

1. As long as the competent authorities of the State States do not have the information or the information required for the execution of these provisions, the internal legislation related to the taxes under which it is understood. They will be subject to the information required to execute their provisions. Any information received by the Government will be kept confidential, such as information obtained within the framework of that State's own internal legislation, and only the tax or collections of the taxes specified in this Statement. will be given to the office or authorities (including forensic authorities and administrative installations) with the executive or punishment of the executive or punishment, and by looking at the work and objections of this matter. These people or authorities will only use the information in the form of these purposes. These people or authorities may open such information in court proceedings or when making judicial decisions.

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

a) administrative or administrative application which does not comply with the legislation or administrative applications of the State taking precautions;

b) obtained within the framework of the legislation or the normal administrative actions of the Keni or the other presenting uninable information;

c) Information that has taken out any commercial, sanni, professional, or trade-action or exporting information that is part of a public order

cannot be interpreted to put it under the obligation.

Article 27

OFFICERS ON THE CHARGE OF THE PLOMATTagPreserver,b,211,216

AND CONSULAR OFFICERS

The provisions of this statement are the officers or consular officers of the diplomat's government. The general rules of the international law, or the provisions of special understanding, will not affect the financial details of the benefit.

Article 28

CURRENT LEAVE

1. Each of the States will inform the State of the State in which it has completed its internal legislation to allow this to enter the current state. This statement will take effect on the date of the last of these notices.

2. The provisions of this statement:

a) January following the current date of the applicable taxes in the direction of the tax on the resource for the first day of the month, or later, for the amounts paid or debunted; and

b) The first day of January following the current date of taxes, the effective date of or for later taxation years

will be applied.

Article 29

CURRENT WITHDRAWAL

1. This will remain in effect until a State of the Force is dissolved by the State. Each of the States has diplomatic means of annulment from diplomatic means at least six months before the end of any calendar year after the conclusion of the story, the company said. It can be annuied by giving it away. Do Not Understand:

a) In the direction of taxes issued in the source, the calendar year given by the annulment of the annulment of the annulment of for amounts paid or charged after the end of the year; and

b) After the end of the calendar year in which the annulment of the annulment is issued, For business-based taxation years

will not be convicted.

COPYRIGHT FOR THESE SERVICES, the full authority on the part of the Representatives have signed this statement.

is organized in the English language, March 2, 2005, in Addis Ababa.

      TÜRKYE A REPUBLIC OF ETHIOPIA IS A FEDERAL DEMOCRAT

           GOVERNMENT ON BEHALF OF THE GOVERNMENT OF THE NAME OF THE REPUBLIC OF ADINA

                       (Israeli)

PROTOCOL

Government of the Government of the Republic of Turkey and the Government of the Federal Democratic Republic of Ethiopia Full-time representatives who signed the Ruling On Preventing Double Taxation In Taxes Over Income, say the provisions of the above are an undivided part of the country. They are understood.

1. 7 Ni-to-Mads:

7 nci, product or commercial product with a location of the 1st part of the Madden. the acquisition of the mirror or similar of the sale of the same or similar commercial activities, the benefit of this action, in the State of the State. If it is proven to avoid the tax, it can be attributed to it rather than.

2. 10 To The 10th Clause:

The terms of the term "Teeth" are derived from the Turkey-direction fund and yacht partner. It will also cover revenues.

TECHNICAL CONTACT, full authority to sign up on the The representatives have signed this Protocol.

is organized in the English language, March 2, 2005, in Addis Ababa.

 

      TÜRKYE A REPUBLIC OF ETHIOPIA IS A FEDERAL DEMOCRAT

           GOVERNMENT ON BEHALF OF THE GOVERNMENT OF THE NAME OF THE REPUBLIC OF ADINA

                       (Israeli)