REPUBLIC OF TURKEYÝLE

PREVENTING TAX EVASION AND TAX EVASION

AGREE TO BE.

MOLDOVAN REPUBLIC OF TURKISH REPUBLIC

RECEIVED FROM THE GOVERNMENT

PREVENTING WITH TAXVERGLÝENDÝRMEYÝ

AND OBSTRUCTION OF TAX EVASION

UNDERSTANDING

REPUBLIC GOVERNMENT

AND

MOLDOVAN REPUBLIC GOVERNMENT

By means of making a comment that prevents double taxation on income and prevents tax evasion">

AVAILABLE TO:

ARTICLE 1

LIMITATIONS

This is the case of one or both of the states of the State of the State will be applied.

MADDE2

KAVRANAN VERGS

1. This information will apply to taxes on income, whether in the form of a Âkit Devlette or political subdivisions, or in the neighborhood administration.

2. All taxes, including taxes paid by total income or income, including taxes paid by taxes on a total amount from the transfer of real estate or real estate assets, or for a total amount of revenue or revenue, will be considered as taxes received from revenue.

3, taxes applicable to the applicable }

a) in the Republic of Turkey:

i) income tax;

ii) institutions tax; and

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

(Will be mentioned as "Turkish tax")

b) in the Republic of Moldova:

i) revenue from the foreign business tax,

ii) Income tax from real people,

(This will be mentioned as "Moldovan tax")

4. At the same time, it will also apply to taxes that are identical to or substantially similar to existing taxes after the signature date of the statement, or rather than the current taxes. The competent authorities of the Aşit States will inform each other of the significant depositions made in the applicable tax regulations.

ARTICLE 3

GENERAL DEFINITIONS

1. For the purposes of this statement, unless the text is predicted otherwise:

a) (i) " Turkey '' s territory in which Turkey has its sovereignty, its territorial waters, in accordance with international law, have not been mediated by the It refers to marine areas that have jurisdiction or sovereignty rights to be used and protected;

(ii) " The Republic of Moldova '' for the Republic of Moldova, and the way it is used in a protected manner, Moldova In accordance with the rules of international law on the Republic of the Republic of The terms of Moldova's sovereignty, including the search and air of resources, and the territory of Moldova, including the common waters and air of air.

b) The terms "A State '' and" in the other ", the terms of the text According to the widget, the Republic of Turkey or the Republic of Moldova means;

c) "Tax '' means any tax which is in the article 2 clause of this statement;

d)" Kishi '' term, a real person, a provision, a company, and any other installation that has made the winter take scope;

e) "The term '' 'means any organization that is treated as an institution, in the direction of any institution or taxation;

f)" Kanuni central' ' term, in relation to the relevant state of the income according to the central meaning;

g) " Citizen '' s:

i) any real person with a citizen of a Akkit State;

ii) A Testicle Devlette Any provision, partner or association with a status-winner according to the legislation in effect

expression.

h)" A request from a Accident State 'S "and" the contact of the other Akuel State' ' terms, which was pushed through a Akitel State concourse, and was pushed out by the State of the Union. The }

i) "Authority" ' s term:

(i) in the direction of the Republic of Turkey, the Minister of Finance or its authorized representative;

(ii) the Republic of Moldova from, refers to the Finance Minister or its authorized representative

;

j) The term "international traffic" has been created by an aircraft or land transmission board, except for the construction of an aircraft or land transport, which is only being actualized within the state of the Dighiner State State. statement.

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 state will have an advantage over the meaning of this term in the current tax legislation.

Article 4

MUKOM

1. For the purposes of this statement, the term " a State of the Instrument State '' is a home, residence, legal center, administrative place, or similar structure, including this State, the political subsection and the neighborhood administration. 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. A real person will be identified in the case of the situation when a real person is identified in the case of the 1st fikra provisions:

a) This is the part of the state in which only a permanent residence exists. will be accepted. If this is a permanent residence in both Develes, it will be considered a common (central part of the vital interest) of the state in which its personal and economic relations are closer (the center of vital interest);

b) Eater. if there is no State that is the center of the vital interests of the business, or if there is no responsibility to remain permanent 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 Develes that will remain in both Develes, or both If such a house is mentioned in the state, it will only be accepted by a member of the state that is a citizen;

d) The United States is a citizen of both states, or if both states are citizens of the State. authorities will resolve the issue with the decision.

3. A third party in which the 1st state of the United States of the United States of the United States of the United States of the United States of America is the only member of the State of the United States, it will only be considered a member of the State of the State.

Article 5

SUBTERNAME

1. For the purposes of this, the term " location '' means a fixed place where the business of a private business is fully or completely executed.

2. The term " Workplace '' specifically includes:

a) Management location;

b) Feb;

c) Bureau;

d) Factory;

e) Workshop, and

f) Any location where the mine is caused, oil or natural gas well, overflow, or natural resources are left out;

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

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

a) The storage of the work bus offerings, only the property or trade of the commerce, use for the purpose of purpose or delivery;

b) The goods and trade assets belonging to the business are only acquired for storage, private or delivery purposes;

c) stocks of business belonging to the company, 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) obtained 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 in the to be held; however, performing these activities together as a result of the collective The activity is set to be prepared or helpful.

5. Except for a part of the 1st and 2nd fikra provisions, except for an agency that is likely to apply a part of -6, a Akitel Devlette moves into the name of a contact and has the authority to acclive to the name of this service. If the company uses its authority from the mutaden, and the activities of the subject are not considered to be in place at the 4th forum, they will not be considered as a place of office, but will do so by any activity in which this person has been resuscied to the case. The application will be accepted with a location in this state.

6. A State of the Union government has a position on the other state in which it conducts its business in a state of emergency, general commission agency, or any agency that is otherwise known as the state of the Republic of Azite. it will not be accepted.

7. A company that is a member of the State of a âcketer, controls or controls a company that is part of the other, or is controlled by, or if it is controlled by it (in a workplace, or in a different way), a company that is the member of the State of the World. will not form an office for any other.

MADDE 6

OBTAINED FROM ASSETS

1. The revenue from real estate in the country of a Profit State (including revenue from agriculture and forestry) is taxable in this other Devlette.

2. The term " real estate '' will be defined according to the legislation of the entity in which it is found. In any case, the term is a real estate property, real estate owned by real estate, agriculture and forestry vehicles and animals (including balm production and its ability), private law provisions. It will cover the rights of the indent rights and mines, resources and other real estate, whether it is fixed or stable; ships, vapes and planes are real estate assets. it will not be counted.

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. The 1st and 3rd fikra provisions will also apply to income from real estate assets used in real estate assets and income from real estate assets in the same time.

Article 7

TERNUM 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 a commercial operation, it may be taxed at this time, with the earnings per share, to be fully axed.

2. The 3rd fikra provisions were found in commercial activity with an area of the State's office in the city of Azite, in the same way that it would have the same or similar activities under similar conditions or similar activities, as a whole. And if every single State of the Azite is going to gain in each of the revenue from the event that we have had a bus, and where it has been happening, a similar amount will be made instead of this job.

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 to the workplace without any profit from this location only when it has been received by goods or commercials.

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

ARTICLE 8

INTERNATIONAL TAILING

1. Earnings from the event of an aircraft or land transmission in international traffic will only be taxed in this Devlet.

2. The purpose of this matter is to use containers as a result of gains in response to gains imposed by a Profitable State team on aircraft construction in international traffic, as well as gains. It will also cover the accidents obtained from the rental.

3. The 1st frikra provisions of this clause will also be applied to a partner, a partner, or any proceeds from an international ticketed agency.

MADDE 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. katýldýðýnda

, and both, both, and financial or financial relations between the two telebuses, both in the management, control or capital of the state government, are expected to be between the two of us, the But this is what we need to be in one of these people, but this is the one that's going to happen. The gain that does not show itself through the conditions is added to the benefit of that contact and may be taxed accordingly.

2. One of the benefits of one of the State's own countries, including the benefit of taxation, may also include the earnings of one of the other State-to-Tax states that are taxed in the country's Profitable State, which is tax-free. At the same time, this first mentioned state of the state, including the benefit, the reported gain, and the people who were going to be among the people who were going to be among those first-mentioned calculations, were subsequently determined as a result of the calculations that were first mentioned in the State. It could be If such a situation occurs, the other state will have to make the necessary corrections to the amount of tax received over the benefit of this regulation, if the state has the opinion that this regulation is right. When making this correction, the other provisions of this will be considered and required by the competent authorities of the United States.

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 according to the legislation, in which the company pays the dividend, and in the case of the true beneficiary of the dividend, the real beneficiary of the case, in this way, will be tax-free. will not take the rates:

a) If the actual beneficiary of the dividend is a company that holds at least 25 percent of the capital of the dividend payout capital (excluding the associates), the amount of the gross dividend amount is 10%

b) 15 percent of the gross dividend amount in all of the other cases.

This fikra will not affect the taxation of a company's earnings during the payment of a company.

3. The term " dividend '' used in this material is based on revenues from stocks, intifas, or inversion rights, which are derived from the founding stocks or those of other rights, which may not be able to bear. 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 Convenience Store, which is in commercial activity with an office in the Diker Azit Devlette, said that after being taxed according to Article 7 of this location, the remaining part of this material is in accordance with the 2-ci fund. It's taxable.

5. The true beneficiary of the dividend, which is a Combat State team, is a business of the company that pays the dividend and is actively engaged in business, if it is found in commercial activity, and has obtained the dividend on the ground. if it is found, the provisions of the 1st and 2nd fikra shall not be applied. In this case, the 7 nci provisions will apply.

ARTICLE 11

FAİZ

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, it may be taxed in the interest of the Atkit Devlette and that state, but the real beneficiary of the interest is the tax, which will be taken in this way, 10 per cent of the gross amount of interest in the interest. It will not.

3. }

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

b) in Turkey and the interest paid by the 2 ci fikra provisions;

b) The interest paid to the Government of Moldova or to the National Bank of Moldova 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 which the debtor is charged. statements. Delay penalties arising from late payments will not be qualified as interest from the purposes of this Article.

5. The true beneficiary of the interest in a Âkit Government team is found in commercial activity with the entity in which the interest is obtained, and if there is an active interest in the interest of the subject, 1 pearl and 2. The nci fikra provisions will not be applied. In this case, the 7 nci provisions will be applied.

6. A State of the State itself, the political subdivision, the local government, or the interest paid by a member of this state, will be considered to be achieved in the State of the United States. 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, because of the actual beneficiary between the payable, or both, or both, and the amount that will be determined between the beneficiary and the leper. On the other hand, these provisions will only apply to the most recent amount of the mentioned quantity. In this case, the payment will be taxed according to the legislation of each of the Azoys by considering the other provisions of this statement.

MADADE 12

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, the cost of the non-unofficial rights may be taxed according to the legislation of the State and the State of the State, however, if the real beneficiary of the non-informal right is a member of the State, the tax will be taken in this way, will not charge 10 percent of the non-Gayrimaddian rights fee.

3. The term "informal rights," which is used in this material, is a form of copyright, artistic or scientific copyright, including bands used in radio and television broadcasts with cinema films, as well as any kind of patent, any kind of difference between the films and the radio and television. The use or use of the model, plan, secret formula or production method, or use or use of scientific or scientific equipment, or use or use of scientific or scientific equipment or use of scientific or scientific equipment. (s)

4. The true beneficiary of the cost of an Akit State is a real beneficiary, if it is found in commercial activity with the entity in which the price is obtained, and the right to be paid, or in between, and the place of this place. if there is an active view, the provisions of the 1st and 2nd fikra will not be applied. In this case, the 7 nci provisions will be applied.

5. A State of the State itself, the political subdivision, the district administration, or the amount of the non-diligent rights paid by a member of this State, will be achieved in the attaché of the Aşit Devlette. However, a person who has paid the non-gaymamadarial claim has the right or the right to pay for the right to pay off an invigorated claim in a Kite State, or have a fixed place, or have a fixed place, or if it has a fixed place. 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 real estate, which is included in the other in the case of a State of the Azoit State, are taxable in this other Devlette.

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. Proceeds from disposal of securities related to the aircraft or land transmission vasses, or aircraft or land transmission vasses, which have been pushed into international traffic, are only in this State of the Republic. will be taxed.

4. Earnings of 1, 2, and 3. In the event of an overhaul of the remaining assets, the proceeds will be taxed only in the State of the World, in which the man is the man who was left out of the world. However, the resulting capital gains will be taxed in the other Profitable State, if the capital in the sentence above mentioned in the above sentence is not a year of increased earnings, economics, and disposal.

MADDE 14

FREE PROFESSION.

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 a person having such a fixed place, the revenue may be taxed in this other State, including only the amount attributed to the fixed site in question.

2. The term "free trade activities" is a scientific, literary, artistic, educational, educational, educational, educational, educational, lawyers, lawyers, engineers, architects, accountants and accountants. scope of activities.

ARTICLE 15

STALE FAILINGS

1. The provisions of the Articles 16, 18, and 19 are to remain withheld, and the fee, salary, and other such proceeds of a Profit Government team shall be taxed only in this Devlet unless it is ifa in the service of the service of the service. 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 service in the Sovereign State of the Republic of America:

a) Revenue resulting in a calendar year that is or ends in the corresponding calendar 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 from a place or fixed place where the business has the other Devlet If not done

will be taxed only on the first mentioned Devlette.

3. The price, salary, and other proceeds of the 1st and 2nd fikra provisions, obtained by a Profit State team, are paid for by a member of a Profit State for the service of the United States. If a plane or land transmission is being performed on an aircraft or land transmission in international traffic, it will not be taxed in this event.

MADDE 16

PAYMENTS TO PRINCIPALS

The administration of a Government team, a member of the Diyakite State team. to be a member of an installed member, the fee and other such payments may be taxed in this language.

ARTICLE 17

ARTIST AND ATHLETES

1. It comes after the provisions of the 14th and 15th articles, the theatre, cinema, radio or television artists, a member of the State of the Republic, and the activities of a musician or an athlete, in the event of the activities of the company in which he/she has performed. It can be taxed in the other Devlette.

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.

ARTICLE 18

RETIREES

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. In addition, this provision will also apply to regular payments for a lifetime of the Government of America.

2. Looking at the 1st of the pearl provisions, pensions and other payments paid within the framework of the social security legislation of a Aper State.

MADDE 19

PUBLIC TASK

1. The State, subdivision or administration fee, salary and other such payments, retired, are retired by a real team of government officials, political subdivision, or neighborhood administration. Only this Devlette will be taxed, including the people.

2. A Department of State itself, political subdivision, or a commercial activity conducted by the neighborhood administration has provisions of 15, 16, 17 and 18 articles of retirement, with salaries, such as salary and other similar payments. will be applied.

MADADE 20

OTHER PEOPLE

The citizen of a Âkit State, or an intern or intern with the purpose of my professional or professional education, only to be found in the State of the World. from the current state of the state in order to ensure they will be able to provide their education or professional skills Payments from sources will not be taxed in this language.

ARTICLE 21

EXTERNAL SERVICES

Where does a ÂKit State team have to do this is earlier The revenue elements that are not specified in their items will be taxed only in this Devlette.

ARTICLE 22

AVOIDÇÝFTE

1. Double taxation for Turkey contacts will be avoided:

a) A Turkey mukimi, (b) an income that may be taxed in Moldova, except for the revenues in the world, except for the avranian incomes of the world. In the event, Turkey will exempt this revenue from tax but will be able to apply a tax rate while calculating the tax on its remaining income, taking into account the exempted income from tax exempt.

b) Turkey is the 4th section of the 13th Amendment, with items 10, 11 and 12 of the Turkish. As a result of a taxable income in Moldova, Turkey will allow a tax on the tax to be paid in Moldova, which hits the revenue of this winter.

However, the subject of the subject is the subject of the For taxable income in Moldova, the amount of tax that is calculated before the crop will not be expected.

2. For Moldovan muids, double taxation will be avoided:

a) When a Moldovan mukimi obtained a taxable income in Turkey according to the provisions of this article, Moldova, the income of this candle is a tax on the The amount of income tax paid in Turkey will allow for a valid amount.

However, the subject of this Article 2 of the article 2 has been subject to the ability to be attributed to taxable income in Turkey. will not increase the amount of calculated income tax.

b) One If the income obtained by any provision of the Moldovan party is exempted from the tax in Moldova, Moldova can take into account the income exempted in the calculation of the tax amount for the remaining income of this candle.

MADDE 23

ALLOCATE.

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 subject to it.

2. Our country's patriarch, a State of Akit, said each of the countries concerned by the relevant State's citizens could be left out of taxation, or less, or less than the taxpayers ' money in which they could be left. they will not be subject to the responsibility.

3. In order to hide the provisions of the 4th section of the 10th Amendment, an area of the Turkish State's foreign policy, in other countries, has less than lehe's taxation, according to the other State's actions, which carry out the same activities. It will not remain.

4. The governments of a State of the World, in which one or a few mutilations of the State of the World, in which the government or its fully capitalises, or are controlled, are the first to be referred to in the state of the state, the state of which is the state of the State. They will not be subject to the taxation or taxation of which they may be, or otherwise, subject to taxation.

5. The interest of the State of the Republic of the Republic of Turkey, except for the provisions of the provisions of the 1st of the 9th section of Article 11, or the rule of six of the 12 articles of Article 11, is the interest and price of interest in the State of the Republic of Turkey, which is paid to a member of the Republic of Turkey in a World of Devotion. In the determination of the taxable earnings of such contact, the payments may be reduced as if they were made to a member of the State originally mentioned in the same conditions.

6. These provisions will not be understood that a Government has to apply discounts to their own people or their familial discounts, as well as to apply the tax and matrah discounts to the Union Government.

MADDE 24

DECISION STYLE

1. One person, in the case of one or both of the countries in the World, has created or created a non-compliance tax on the provisions of the Union, and the state of the United States, in the case of domestic legislation, has been avoided. the authority of the government in which it is a citizen of the state, in accordance with the state's authority or the 1st of the 23rd Article, may be able to supply the authority of the State to the authority of the State of the State. It is necessary to do so within the time specified in the internal regulations of the states.

2. If a satisfactory solution is not resolved, the competent authority will strive to understand the country's competent authority, in an effort to avoid any further taxation of the State of the United States.