f) "The contact of a Monopoly State" and "the contact of the other State of the World", a policy that has been pushed out by a Kite State team, and in the case of the " It makes sense for a government that has been pushed out by the government;

g) The term "international traffic" is the ship, except for the construction of a ship or aircraft that was made solely within the states of the Exchange State of a Kite State. or the aircraft is being pushed to the task;

h)  The term "competent authority":

i) refers to Lithuania, the Finance Minister or its authorized representative;

ii) in the direction of Turkey, the Finance Minister or its authorized representative;

;

i) The term "Citizen" refers to any real business that is a citizen of the Government, and any other, partner, association or other organization that earns a status according to the legislation in effect in a Aper State.

2.  As a result of implementation of this information on any date by the State, any term that is not defined in the expression is subject to the purpose of the purposes of the State of the State, at the time of the purposes of the tax purposes, unless the text is otherwise known to the contrary. the meaning of this term and the meaning of this state in the current tax legislation.

MADDE 4

MUKOM

1. For the purposes of this statement, the term "A State of the Instrument ''" is the state of the state, including this State and its district administration, as well as the home, residence, the legal center, the place of administration, the institution of the institution or any other. Due to the criterion, the taxpayer will be meaningful. However, this term does not cover any amount of money that is subject to tax due to the revenue generated from sources in that state.

2.  The state of the following will be determined by the state of the state in which there is only one actual person to whom it is the only part of the world:

a) The state of the state in which a real person is found to be a real person. will be accepted. If there is a home in both Devlette, the state will be considered a member of the state of the state (which is the center of vital interest) for its personal and economic relations;

b) if there is no state where the center of the vital interests of the life is not detected, or if there is no house that will remain diimical in both Devlette, a member of the state where the home has been found only to remain in place;

c) If there is a house in both Devallette, or both Devlette, both Devlette and the If such a home is not the case, it will only be accepted by the state of the state where it is a citizen;

d) The competent authorities of both states, if they are citizens of both states, or both state citizens. they will resolve the issue with the understanding.

3.  The authorities of the United States have agreed to resolve the issue and determine the way it will be applied to it, according to the officials of the Real State, and the authorities of the State of the World in which both of the countries of the pearl of Azor Azite were. They will. If such an understanding is not available, it will not be considered a member of any of the United States to take advantage of the provisions of this part.

ARTICLE 5

ITYERITEM

1.  The term "workplace" for the purposes of this statement comes to a constant state of place, where the business of a private business is completely or completely executed.

2.  The term "workplace" is especially covered by the following:

a) Management location;

b) Feb;

c) Bureau;

d) Factory;

e) Workshop, and

f) Any location where the maden stove, oil or natural gas well, overflow or natural resources are roped in.

3.  A construction, assembly, or installation project, or any control activities associated with them, will be available only when the project or activity continues for a period of nine months.

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

a) The storage of the same and only property, or business, of the business, is the property of the city. or its use for delivery purposes;

b) Inventory of the commodity or trade belonging to the business, only for storage, contact, or delivery purposes;

c) stocks of business belonging or commercials belonging to the business, the purpose of getting started with only one person;

d) A fixed place where a fixed location is only available for purchase or collection of goods or commercials;

e) is a fixed location for a stable location, ready for service, or help for a private bus. elde

f) To perform one or more of the activities mentioned in a fixed location, only a) and e) to perform one or more of the activities mentioned; as a result of the execution of all of these activities in the fixed place. prepare for the activity and help it qualify.

5.  The 1st and 2nd fikra provisions of the United States have the authority to move to the name of a transaction in the event of an emergency vehicle, acting as a service to the power of a transaction, in the case of the agency, which is likely to be applied to the right of the sixth and second. If you use the authority, the activities of the person in this State of the State will not be available for any of the activities specified in the 4th forum and not from the nature of the activity which did not make this place available if the business was made from a fixed location. It will be considered to have a location.

6.  A State of the Union government has a position on the other State of the Republic, only to have its own people in a state of emergency, general commission agency or any other agency that has the status of an agency that is not in the state of the Republic. It won't be accepted. However, the agency's actions have been completely or completely different from the fact that the agency is aware of the fact that it should be in the process of being among those people who are looking for things between this agency and those people in the region. It will not be considered as an agent in status, in which case the provisions of the 5th fikra will be applied.

7.  A company that is a member of the State of a âite, a member of the Devilitet State, or a company that is engaged in commercialized activity (in a workplace or other province), controls a company or is controlled by it. will not form an office for any other.

MADDE 6

OBTAINED FROM ASSETS

1.  Income from the real estate assets found in the other Akit Devlette (including revenue from agriculture or forestry) may be taxed in this other Devlette.

2.  The term "real estate" will be defined according to the legislation of the entity in which it is located. The fact that the real estate provisions of real estate are the tools and animals used in real estate, property and property of real estate, the real estate property, the real estate property, applies to real estate. They will cover the rights of their rights and mines, resources and other resources, or rights over payments, which are fixed or fixed, while ships, vats, and planes will not be counted as real estate.

3.  The 1st fikra provisions will apply to the revenue generated from the use of real estate, leased or otherwise used in any other way.

4.  If the person who owns shares or other company rights holds the right to benefit from the real estate assets that are owned by this stock or company rights, then use the rights of the subject for the use of the income from the lease or use of any other country may be taxed at the Okit Devlette.

5.  The provisions of 1, 3, and 4 will also apply to the revenue from real estate assets and the proceeds from real estate assets.

MADADE. 7

TOTAL EARNINGS

1.  The gain of a Profitable State government will be taxed only in this State, as it does not engage in commercialized activity in the case of the telemarkeet, in the case of the teleport, the Turkish in the country. If the United States has engaged in the above mentioned business, it may be taxed in this country's earnings, which can be attributed only to the amount of money that can be attributed to the company. However, this is the property that has been made with the location of this location. Gains from the execution of the same or similar sale of the trade or the same of the same or similar activities, such as those of the same kind of selling or similar activities, are expected to avoid tax in the country where the business is located, or If it is accepted, it can be attributed to this location.

2.  The gain would be attributed to the workplace in the same way as the same or similar conditions that would be attributed to the site in both of the Azoit States, as the 3rd fikra provisions were found in a commercial operation in a State of the Republic of Azite, in the event of a State of the Republic of Azite. It will be a total benefit if it is a total benefit of the exact same or similar activities, such as a fully separate and non-view, and will gain a full benefit from the person who has the location.

3.  When determining a location, you will be allowed to download expenses that are in place for the purposes of the office, including the management and general administration expenses, which are located in the State of the State or anywhere else.

4.  No gain will be made at any cost to the site of the sale of goods or commercials by this location alone.

5.  The provisions of this clause will not be affected by the provisions of this clause as well as the revenue elements that are organized separately in other articles.

MADDE 8

DENNZ AND AIR TAXABLE

1. In the international traffic, the profits from the ship and the aircraft carrier will only be taxed in this State.

2. The 1st frikra provisions will also be applied to a partnership, a partner, a partner, or an agency that operates an international agency.

MADADE 9

BASED CONTACT

1. a) In the management, control or capital of the Government's government, or

b) a Indirect State, or indirectly, in the case of a State of the State's foreign policy, or indirectly, a Âkit State community. The management, control or capital of the state government,

and, both, the conditions for which the trade or financial relations between the two buses were created or created, should be between the two of us, The conditions that must be, but have been, or are, different from the conditions. Because of the fact that, due to the fact that the benefit is not self-represented in one of the countries, it is added to the benefit of that contact and may be taxed accordingly.

2. When a State of the âite State has been included in the earnings of its own country and its taxation, in the Profitable State, in which the state of the state is taxed and said, the first mentioned state is the benefit of the state of the state, and the first time the state has ever been mentioned, the state of the country has won the first ever mentioned state. As a result of the fact that the state of this specification is in place, given the conditions that need to be made in front of the first mentioned State of the United States, the State of the United States of the United States will not be able to use the same will make the necessary corrections to the quantity. When making this correction, the authorities of this Union will be kept in mind and required by the competent authorities.

ARTICLE 10

THEMES

1. A dividend paid by a company that is the party of a State of the State may be taxed in this other Devlette.

2. However, they may be taxed on the fact that the company that pays the dividend is a member of the government and the legislation of this state, but the real beneficiary of the dividend is the tax effort that will be taken in such a way that the State of the World is a true beneficiary. It will not address 10% of dividend amount.

This fikra will not affect taxation of a company in relation to a dividend paid from it.

3. The term "dividend", used in this material, is based on revenues from stocks, intifas, or indent rights, which are derived from the founding stocks or those of other rights, which may not be able to bear or contribute to the profits. Refers to the revenue generated from the other company's right to receive the same treatment as the revenue from the taxation-driven stocks, according to the legislation of the state in which the company is the person.

4. The winner of a Âkit Government company, which is engaged in a commercial operation with a place in the country in which it is located, is taxed according to the 7th State of the Union, after being taxed according to Article 7 of this article, in accordance with the 2nd of this Article. .

5. The true beneficiary of the dividend, a Combat Government team, said that the company, which pays the dividend, is engaged in commercial activity, or in a stable place in Lithuania, where a Turkey is located in a stable location. If there is a free trade activity in Lithuania and there is an active part of this place or fixed place, the provisions of the 1st and 2nd fikra will not be applied if the fact is that there is an active connection between the fact that it has obtained the dividend. In this case, the provisions of 7 nci or 14th clause shall be applied.

6. The 4th fikra provisions of this Article are intended to be saved by a company with a State of the Republic of Turkey, in the case of income or gain from the State of the Union, to be paid to one of their own mutilations or to obtain dividend. It cannot receive any tax on the dividend paid by this company, except with the status of an office located in the other State or a fixed site, except that they have an active experience. In the same way, such State, paid dividend or disdain is a tax on non-imposed earnings over the non-imposed earnings of this company, regardless of whether or not it is the result of the acquisition in total or not. not.

MADDE 11

FAIAZ

1. The interest paid to a member of the Instrument State and the other in the realm of the other in the Devlet State may be taxed on this other Devlette.

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 State of the State, which will receive 10 per cent of the amount of interest in the interest of the interest. It will not.

3. }

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

b) The interest paid to the Government of the Republic of Lithuania or the Bank of Lithuania in Turkey will be exempted from the Turkish tax.

4. The term "interest", used in this material, is derived from any kind of credit or debt denominated income, in any kind of creditless revenue, and especially public securities, regardless of the mortgage guarantee or the debt to the debt. statements and express their bonus and bonuses. Delay penalties arising from late payments will not be qualified as interest from the purposes of this Article.

5. The interest beneficiary, an interest in the State team, is found in commercial activity in Lithuania, where the interest is obtained, or in Lithuania, Lithuania using the fixed place in Lithuania in the country. If it is found and there is an active view of this office or fixed site, the provisions of the 1st, 2nd and 3rd fikra will not be applied if the subject of the subject is found to be paid. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

6. It will be accepted that the interest paid by a member of the State of a âite will be obtained in that Aşit Devlette. However, the interest-paying person is either a member of a Kite State, or if the fact that it has a fixed place, whether it has a fixed place or a fixed place, with the debt-to-credit relationship that is causing interest to pay off in a World of Love, and interest is not on the site or the fixed place. It will be considered to be acquired in the Fuel State, where the location or the fixed location is located.

7. The amount of interest paid in the credit is due to the fact that there is no such relationship, due to the fact that there is no such relationship, because of the actual beneficiary between the payable or both, or both, and the amount of money that is not. On the other hand, these provisions will only apply to the most recent amount of the mentioned quantity. In this case, the additional payment will be taxed according to the legislation of each of the Azoys.

NON-INFORMAL RIGHTS

1. The non-gayrimadm rights, which are paid to a member of a Âkit Devlette and in the other, may be taxed on this other Devlette.

2. However, it may be taxed according to the State of the World and the State of the State in which they are entitled to the non-unofficial rights, however, if the true beneficiary of the non-purpose of the non-informal right is a member of the State, the tax will be tax on:

a)% 5% of the non-effort and scientific equipment paid,

b)% of the amount of non-unofficial rights of all non-states. 10 of

will not be able to start.

3. The term "unofficial rights costs" used in this material, including films or bands used in radio and television broadcasts with movie films, and any kind of copyright, any kind of patent, any kind of patent, any kind of difference. the use or use of the model, plan, secret formula or production method or use or use any of the information, trade or scientific equipment, or use of scientific, trade or scientific equipment or use of the production method. They cover any payments that are made.

4. The true beneficiary of the cost of an Akit State is a true beneficiary, if found in a commercial activity in the country where the price was obtained, or use a fixed place in Lithuania. if they are found in free professional activity and there is an active view of the right or the right to be paid, the 1st and 2nd fikra provisions of this item shall not be applied. In this case, the provisions of the 7th or 14th terms shall be applied according to the event.

5. It will be accepted that the price of an entity paid by a member of the State will be achieved in the transfer of the Aşit State. However, the person who paid the non-purpose of the non-diligent right has a claim or lack of merit, or a fixed place, with the right or the heir to pay the price of an invigorated rights in the State of a Endeavor, and the non-diligent right of the State. If the price is being downloaded by this location or fixed site, it will be considered to be obtained in the Policy Policy of the cost, location, or fixed location.

6. The use of the amount of diligent rights paid in rights or information is the actual beneficiary between the payable and the actual beneficiary, or both due to the fact that there is no such relationship, due to the special relationship between the other and the actual beneficiary. 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.

CAPITAL CAMELARTIÞ

1. Earnings per share of the real estate holdings or real estate assets that are listed in the 6th part of the State of the Republic of Turkey, or the real estate assets listed on the 6th Amendment, are the benefits of this property. It can be taxed in the state.

2. Securities owned by a company owned by a company owned by the other in the other in the Âkit Devlette, or in a fixed location to perform free business in the case of a Âkit State team. Earnings per share may be taxed in this language, including the benefit of this location (either with or with all contact), or from an overhaul of the fixed site.

3. Earnings from the disposal of securities related to the ship or aircraft or aircraft or aircraft being pushed into international traffic will be taxed only in this State when a ship or aircraft or aircraft or aircraft or aircraft or aircraft is being pushed to the international traffic.

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.

MADDE 14

FREE OCCUPATION FAALILERS

1. As long as a Profit has been achieved by the State of the Union, it has acquired free professional activity or other activities, as long as it does not have a constant place to use it in order to perform its activities in the other, in this case, in the case of the other in the region. It will only be taxed on this state. In the case of having such a fixed place, the income can be taxed in this other State, only to be left with the amount that can be attributed to the fixed place in question. If a true part of a State Government has such a fixed place, but it remains a total of 183 days or more at a time of any 12 months that either start or end in the relevant property in the other in the Aper Transfer State. will be considered to have a fixed place that is regularly useful in this camel, and the proceeds from the above mentioned activities in this state will be able to be attributed to this fixed site.

2. The term "free trade activities" is a scientific, religious, artistic, educational, educational and educational activities that are carried out in particular, as well as the doctors, lawyers, engineers, architects, workers, accountants. scope of activities.

STALE FAILINGS

1.  16, 18, 19, and 20 are the provisions of the articles of a State, a charge of service, the salary, salary, and other such proceeds will be taxed only in this Devlet unless it is performed in the other Profit Inherit. If the service is executed in the other Devlette, the proceeds from here may be taxed in this other Devlette.

2.  Looking at the 1st of the pearl provisions, a PROFIT STATE has achieved a non-profit in the state in which the State has achieved a service, the following:kiþi

a) Revenue resulting in revenue from the other state in the related fiscal year. if a total of 183 days in no twelve month period, and

b) Payment is done by an issuer who is not the member of the other State or such an issuing name, and

c) Payment is not made from a place or fixed place that the owner has in the other state will be taxed only on the first mentioned Devlette.

3.  The revenue generated by the previous provisions of this Article may be taxed in this State when a member of a Akitel State, a ship in international traffic, was executed in traffic or a service indirect on a plane.

MADDE 16

PAYMENTS TO MANAGERS

The fee and other such payments that a Profit Government has obtained with the fact that a company with a member of the Dikit Government is a board member or a member of the supervisory board, and so on, this is the It can be taxed in the state.

MADDE 17

ARTIST AND ATHLETES

1.  An artist or a musician, or a musician, or an athlete, is an artist or an athlete, regardless of the provisions of the 14th and 15th articles, the theatre, cinema, radio or televzion artist, or an athlete, has been performed in the Akkit Area. income, which may be taxable.

2.  The income of an artist or sportsman from the activities of the artist or the sport itself, if directed to a woman, is an artist or athlete who is not alone with the provisions of 7, 14, and 15. is taxable.

3.  In the event that an artist or athlete performs activities in a Âkit Devlette, this Devlette visit is entirely or significantly in support of one of the countries, or the public funds of one or two, of 1 and 2. The provisions of the fikra will not be applied. In such a case, the revenue in such a case may be taxed only by the artist or athlete.

ARTICLE 18

PENSIONERS

1.  Pensions and other such payments, paid for by the passage of a US State team, to remain withheld by the provisions of the 1st of the 19th Article, will only be taxed on this State. This provision will also apply to regular payments made to a Akkit State.

2.  The term "regular payment" is a lifetime or a period of time for the fulfillment of a full or sufficient return payment obligation, or in a period of time period, with money or money, in certain times. represents a total amount to be specified in a measurable benefit.

ARTICLE 19

PUBLIC RETURN

1.  Services issued by the State or administration of the State or administration of the State or administration of the State or administration of this State or administration are provided by the State or Administration of a fee, such as this State or other, but only in this State. will be taxed.

2.  A fee of 15, 16, 17, and 18 will apply to the retired people, with the fee, salary and other such payments that are carried out by the State of the State itself or the financial services carried out by the government's office. MADDE 20

PROFESSIONALS, PROFESSORS AND RESEARCHERS

1.  In the event of a visit to the State of Azor, or just before his visit, the first mentioned State of the State, a student in the State of the State, or the other person who has been involved in the course of my career, has seen his career, or his livelihood, his career. Or, payments made from sources in this State will not be taxed in this State.

2.  The first visit of a real person who has visited and visited a University, a university, a high school, or other than the other, visited and made a visit to the country in the first place, and before. Any fees that are available for a period of no less than two years from the date of the date will be the exception of the first mentioned State of the State, with the exception of the data from the resources.

3.  If the public benefit of the investigation activity is not, primarily for the specific interest of a particular person or people, the 2 nci provisions of this material will not be applied to the revenue generated from these activities.

MADDE 21

LANGUAGE CELLS

1.  Any revenue elements that are not specified in any of the preceding items of a Âkit Government contact 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 mentioned income of a State of the Profit is found in commercial activity with an office located in the other Profit Transfer State, or a If Turkey performs free professional activity from a fixed site in Lithuania, and a significant number of people are involved in the right or fixed place with a fixed place or fixed place, then the 1st frisk provisions will not be applied to this income. In this case, the provisions of article 7 or 14th will apply.

ARTICLE 22

PREVENT">

1.  Lithuania will avoid double taxation for its muids:

A Lithuania candle is more advantageous in its domestic legislation when it has a taxable income in Turkey, according to the provisions of this clause. as long as there is no application, this will allow the revenue of the person to be subject to the income tax paid in Turkey.

However, the subject of the subject is taxable income in Turkey. The income tax calculated in Lithuania before the maphsupate can be attributed will not be able to increase the amount.

2.  Double taxation for the Turkish people will be avoided:

a) A Turkey mukimi, (b) excluding the revenues in the self, is a taxable income in Lithuania according to the provisions of this Judgment. In the event, Turkey will exempt this revenue from tax, but will be able to apply a tax rate while calculating the tax on the remaining income of this person, taking into account the exempted income as being exempt from tax.

b) Turkey is in Lithuania, according to Articles 10, 11 and 12 of the Turkish When a taxable income is obtained, Turkey will allow a tax on the tax paid in Lithuania, which hits its revenue.

In addition, in Lithuania, in the case of the subject of the For taxable income, the amount of tax calculated before the crop will not take place.

ARTICLE 23

FAILURE TO DO">

1.  The citizens of a State Government, in the same way, are responsible for taxes, especially in the direction of the government, or the liability, especially in the direction of the government, of the country's citizens, in particular, in the case of taxation and the need for a greater amount of taxation. They will not be subjected to taxation and to those who are not. This provision will also apply to the non-connotiv of one or both of the states, or both, with the provisions of the 1st clause.

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 Devlet, is less lehe's taxation than those of the other State, who are conducting the same activities as the other State. He's not going to get involved. This provision would not be understood that the State has to apply the discounts, taxes and matrah discounts to the Government of the Republic of America.