Read the untranslated law here: https://www.tbmm.gov.tr/kanunlar/k4526.html
Law No. 4526:1.2.2000 article 1. – June 25, 1998, the Government of the Republic of Turkey in Chisinau with the Government of the Republic of Moldova signed "Call Comes from Me on a double taxation and tax Tax recognized in Al Smuggler From agreement" for the attachment of "confirming" reputation Protok. Article 2. – This law enters into force the date of promulgation. Article 3. – This law the provisions of the Council of Ministers.
The GOVERNMENT of the REPUBLIC of TURKEY, the GOVERNMENT of the REPUBLIC OF MOLDOVA with DOUBLE TAXES on INCOME BETWEEN the VERGLİENDİRMEYİ PREVENTION and the GOVERNMENT of the REPUBLIC of TURKEY and the AGREEMENT to STOP TRAFFICKING of TAXES of the REPUBLIC OF MOLDOVA to prevent double taxation of income obtained through GOVERNMENT taxation and tax FOLLOWING a deal that prevent trafficking accord agreed upon: article 1 PERSONS COVERED UNDER this agreement, for Âkit, from the people who are residents of one or both of the apply.
Article 2 the AFORE MENTIONED DATES, TAXES 1. This agreement, regardless of how it is taken, the lower parts of a Âkit State or political or local auxiliaries will be applied to the income obtained through taxes.
2. Securities gains arising from the transfer of assets or real estate taxes are applied to the total amount of wages or salary with paid by undertakings through taxes total income or revenue, including all taxes, income obtained through elements taken from the taxes will be considered.
3, of this agreement will apply to currently valid tax are in particular: a) Republic of Turkey: I) the income tax;
II) the corporation tax; and iii) income tax and corporate tax share of funds obtained through;
(From now on referred to as "Turkish tax") b) Republic of Moldova: I) taken from income tax, attempted ii) taken from income tax, real people (henceforth referred to as "Moldovan tax".)
4. after the date of signature of the agreement the agreement at the same time, in addition to or instead of their existing tax and received the same quality of existing taxes or significantly similar to them will also be applied to taxes. Âkit States ' competent authorities, related tax legislation will notify each other of important changes in. Article 3 GENERAL DEFINITIONS 1. For the purposes of this agreement, unless the text otherwise predict: a) (I) the term "Turkey '' Turkey has sovereignty of the area, in accordance with international law, the territorial waters, but also the investigation, operation and conservation of natural resources for purposes of jurisdiction or sovereignty rights refers to the sea areas;
(ii) the term "the Republic of Moldova, the Republic of Moldova and geographical sense '' is used, the Republic of Moldova in accordance with the rules of international law on natural resources and securing the sovereignty for rights including internal waters and airspace has sovereignty of Moldova refers to the field.
b) "Âkit State" and "the other Âkit to the requirements of the State '' term, text, Turkey Republic or Republic of Moldova means;
c the term "tax '') this agreement is grasped in article 2 refers to any tax;
d the term "person a real ''), a constructive party, a company and any other body of people gets covered;
e the term "company) '' as an institution, in terms of taxation of any institution or treated means that any organization;
f the term "Legal Center '' Âkit) States according to the relevant laws means the registered Centre; g) "Citizen '' term: I) A Âkit State any real people have the citizenship;
According to the legislation in force in the State on a Âkit II) status the person, partnership or Association of any winning hereinafter granted.
h) "attempted '' A Âkit State and" other Âkit attempted '' terms of the State respectively, a resident of the State-run enterprises and other Âkit Âkit means a State resident-run enterprises;
I the term '' competent authority "): (I) the Minister of Finance of the Republic of Turkey, or his authorized representative;
(ii) the Minister of finance or in terms of the Republic of Moldova refers to the authorised representative;
j the term "international traffic ''), performed within the boundaries of the State only other Âkit aircraft or land transport by means of a Âkit, except for State aircraft or land transport means by the attempt been made to transportation. 2. a Âkit of this agreement at any time by the State in relation to the implementation of any term that is not defined in the agreement, the text of the agreement is to be applied, unless you anticipate otherwise for the purposes of the tax, at the time, this has meant that the State legislation and state tax legislation in force in this State, other legislation, a sense that the advantages will carry the meaning given the term.
Article 4 RESIDENT 1. For the purposes of this agreement, the term "resident of a Âkit State '' that State, political subdivision, and the local administration in accordance with the legislation of the State, including home, residence, place of management or similar structure, other legal Center, one of the criteria means that the taxpayer is due to people. However, this term does not come from Government sources only due to that taxable does not cover any person held.
2. the provisions of paragraph 1 and therefore a real person is resident in the State on both Âkit, that person's status will be determined in the following manner: a) this person, only permanent residents of the State where a "domicile, which can as will be accepted. If this person can remain permanently at both State if you have a home, that person is personal and economic relations are closer (Centre of vital interests) will be treated as a resident of the State; b) If the person's vital interests cannot be determined, or the center of both the State and the State can remain as a permanent residence or, this person only where the State House acquired menstruation to remain a resident will be accepted;
c) If the person has acquired menstruation to remain at both State House or a House that is not in question, both in the State, that person shall be deemed a resident of the State, it is only the citizens;
d) if the person is a citizen of both the State and the State also is not a citizen of either or both, Âkit States competent authorities by mutual agreement to solve the problem.
3. the provisions of paragraph 1 a person other than a natural person, hence both Âkit and resident of the State, this person only as a resident of the State headquarters of the lawful will be accepted.
Article 5 ESTABLISHMENT 1. For the purposes of this agreement, the term "workplace '', is being carried out, in whole or in part of an undertaking relating to the work means a fixed location.
2. the term "Workplace '' in particular gets covered: a) management;
e) Workshop, and f) mining, oil or gas well, a quarry or any other place where natural resources; 3. a period of Twelve months is an ongoing construction site, construction or building project creates a workplace.
4. the provisions of This article is connected with the earlier accepted the term "workplace '' shall be deemed not covered by the following points: a) belongs to only of Attempted Enterprise goods or commercial goods for the purpose of storage, display or delivery;
b) stocks of goods and commercial goods belonging to the Enterprise solely for the purpose of storage, display or delivery kept getting;
c the goods belonging to the Enterprise and commercial goods stocks), only for the purpose of processing by another enterprise kept getting;
d only a fixed place, for Work) to commit to purchase goods or commercial goods or information gathering purposes, kept getting;
e to a fixed place for Work, attempt) is only preliminary or auxiliary character for the purposes of the execution of any other work kept getting;
only a fixed place for Work f), a) with e) mentioned activities between one or more paragraphs on the way, kept getting a to perform; but those activities exercised as a result of a combination of collective activity preparatory or auxiliary character manifesting itself.
5. the provisions of paragraphs 1 and 2 of a person connected with accepted-6 of clause will apply except for a independent agents-Âkit and act on behalf of an undertaking in the State on behalf of the akdetme contract is authorized to attempt the authority uses and activities of the person in question ordinarily fourth paragraph will be considered work made from the specified fixed place is not limited to, the activities carried out in the name of all kinds of attempted this person's activity therefore attempted , has an Office in this State will be accepted.
6. A Âkit State Âkit State jobs, other attempt only their business as usual is an ongoing General Commission agent, or broker, independent status to any other agents, carried out through a permanent establishment in the State that has accepted the other. 7. a company with A State resident of Âkit, a resident of the State or other Âkit that controls a company operating in the other State, commercial or by checks (through a permanent establishment or otherwise), this company will not create an Office for any of the other.
Article 6 REAL ESTATE ENTITY REVENUES 1. A resident of the other State a Âkit Âkit revenues from real estate assets located in the State (including income from agriculture and ormancılıktan), that other State, be taxed.
2. the term "real estate assets '' out of the question according to the legislation of the State where the entity Âkit will be defined. The term in any case real estate asset müteferri assets used in forestry, agriculture and tools and animals (including production and fish farming), to be applied to the provisions of private law rights to real estate ownership, usufruct rights, real estate and other resources of mines and natural resources operation or business as fixed or variable payments arising in Exchange for the rights to cover; ships, boats and aircraft real estate asset will not be counted.
3. the provisions of paragraph 1, arising from the use, rental real estate entity directly or other statement of income earned from the use in any way.
4. the provisions of paragraphs 1 and 3rd at the same time, the income of an enterprise real estate assets with real estate assets used in self-employment activities Executive will also be applied to income from.
Article 7 COMMERCIAL EARNINGS 1. The Government attempted a Âkit gain, such a workplace other Âkit attempted State unless the trade activity through, only this would be taxed in the State. If the aforementioned way attempted commercial activity, the enterprise gains attributable to the workplace this other State, only to be limited to the amount to be taxed.
2. without prejudice to the provisions of 3rd paragraph, attempted a Âkit State Âkit State through a permanent establishment situated in the other commercial activity is found, if this Office is under the same or similar conditions, in the same or similar activities were a completely separate and independent enterprises and businesses completely independent attempted create quality had won what will each gain a Âkit State is that a gain the same amount of Office atfedilecektir.
3. in determining the earnings of A workplace, where the State Office or at any other location, management and general administration expenses fall within the scope of the field office will be allowed to achieve the appropriate download falling costs.
4. the establishment of the Office by taking goods or commercial goods only on behalf of attempted thus no gain atfedilmeyecek.
5. Gain, held separately in other articles of this agreement income elements also fall within the scope of the provisions of that article when this article from will not be affected.
Article 8 INTERNATIONAL TRANSPORT 1. A Âkit Government attempted from a plane or ground transportation vehicles in international traffic has achieved gains, only vergilendirilebilecektir in this State.
2. for the purposes of this article, the international traffic of aircraft operations in a Âkit State enterprises gain achieved by the provisions of paragraph 1 is to be applied in addition to incidental gains, achieving as a container from the use of or rent g: will cover are obtained from.
3. the provisions of paragraph 1 of the present article also operated an affiliate business or a partnership, an international agency will be used to gain participation thus obtained.
Article 9 DEPENDENT UNDERTAKINGS 1. Âkit a) a State initiative, either directly or indirectly, the management, control or attempt other Âkit State capital joined to, or b) the same persons, either directly or indirectly attempted a Âkit State Âkit State enterprises of management, control and other or joined to the capital, and either way, the two attempted to impose trade or financial relations between or among the conditions the formation of independent undertakings when required conditions different , this should be one of attempted, but these conditions and therefore does not present himself, he would be added to the earnings and accordingly taxable enterprise. 2. A Âkit State so on their own initiative, one of which included earnings vergilediği earnings, other Âkit one of these other government enterprises vergilendirilen in the State also can include earnings. At the same time, this has included the first mentioned State attempted gain, reported earnings, will consist of relationships between independent undertakings, taking into account the State executed the first mentioned of calculations can be determined as a result of earnings. Such a situation when you show yourself, if the other State if it comes to this edit is right, the amount of such earnings in tax over perform the necessary corrections. Any other provision of this agreement, when this correction eye will be kept and, when necessary, in front of the Âkit States competent authorities danışacaklardır to each other. Article 10 DIVIDENDS 1. A company with a State resident of Âkit by other Âkit a resident of the State, that other State taxable dividends paid.
2. However, such dividends, temettüyü paying company is resident in the State, and according to the legislation of this State Âkit to be taxed; However, the dividend is a resident of the State, the real beneficiary other Âkit, in this way, tax shall not exceed the following rates: a) Temettünün real beneficiary, paying dividends the company's share capital directly on the hands of at least 25 percent of the company (except for partnerships) gross amount of dividends 10%;
b) in all other cases, the gross amount of the dividends 15 percent.
This clause, a company paid dividends shall not affect the taxation of non-profits.
3. the term "dividends '' is used in this article, the redeemed promissory notes or stocks, usufruct rights, founder shares will not profit from or provides other rights to participate in the nature of income is a company engaged in the distribution of resident with the State according to legislation, taxation income from stocks in terms of seeing the same treatment other company rights refers to the resulting revenues.
4. Other Âkit through a permanent establishment situated in the State commercial company gain a Âkit operating in the State, where the establishment of Âkit after tax 7 according to the article in the State, the remaining part of this article in accordance with paragraph 2 of the taxable.
5. A resident of the State is the real beneficiary of dividends Âkit, temettüyü is located in the State of the other company's resident who paid Âkit via a commercial activity in the workplace and among the establishment with the event dividend in question obtained depends on an active East-side profile is written in Spanish, the 1st and 2nd will not apply the provisions of paragraph. In this case, the provisions of article 7 shall apply.
Article 11 INTEREST 1. A Âkit is a resident of the other State, and paid interest, Âkit State that other State, be taxed.
2. However, this interest is obtained according to the legislation of the State Âkit State and taxed; However, if a resident of the other State's real beneficiary interest Âkit tax in this way, interest shall not exceed 10 per cent of the gross amount.
3. irrespective of the provisions of paragraph 2, a) born in Moldova and Turkey paid interest to the Government or Central Bank of the Republic of Turkey Moldova will be exempt from tax;
b) born in Turkey and paid to the National Bank of Moldova Moldovan Government or interest will be exempt from Turkish tax.
4. the term "interest" is used in this article, '' depending on the guarantee, mortgage, whether or not you know the right to participate in the earnings of the debtor or recognition, suitable for all kinds of proceeds arising from receivable and especially public securities with proceeds from the bond or debt securities. Delay resulting from late payment penalties, for the purposes of this article, interest will not be called. the interest is a resident of State a Âkit real beneficiary interest obtained through a permanent establishment situated in the other Âkit State commercial activities and will take such an active interest paid depends on if this Office with is written in between 1st and 2nd, the provisions will not apply. In this case, the provisions of article 7 shall apply.
6. Âkit State itself, political subdivision, A local authority or a resident of this State by Âkit interest paid will be considered that is obtained in the State. However, a resident of the State where the interest payer, whether or not a Âkit a Âkit debt interest payment in the State will take in connection with the relationship why a business, or a fixed-place and is installed by this establishment or fixed place of interest, such interest, the establishment or fixed place where the Âkit will be considered obtained in the State.
7. the amount of interest paid Will, with beneficiaries, or between a payer and both with another person because of the relationship existing between private, in the absence of such a relationship between the payer and the beneficiary exceeds the amount be determined, the provisions of this article shall apply only to the most recent mentioned amount. In this case additional payment, and any other provision of this agreement, taking into account the State of the legislation will be taxed according to each Âkit.
GAYRİMADDÎ RIGHTS article 12 FEES 1. A Âkit is a resident of the other State, and Âkit gayrimaddî rights fees paid to the State, that other State, be taxed.
2. However, such costs were obtained from Âkit State gayrimaddî rights and according to the legislation of the State taxed; However, the real beneficiaries of the rights of other gayrimaddî Âkit is a resident of the State, tax in this way, the cost of 10 percent of the amount of gayrisafî gayrimaddî rights shall not exceed the flour. 3. In this article the term "gayrimaddî rights fees '' that can be used, with radio and television movies including bandwidth used in literary, artistic or scientific, suitable for all kinds of kinds of copyright, patent, the distinguishable, pattern or model, plan, secret formula or method of use or right of use or manufacture of industrial, commercial or scientific experience-based knowledge or use of industrial, commercial or scientific equipment, or use as any payment made in Exchange for security.
4. the cost of A Âkit State gayrimaddî rights of residents of the real beneficiaries, the price in question was obtained through a permanent establishment situated in the other Âkit State commercial activity is found and paid the price in question with the rights or assets if an active bond between the establishment of the 1st and 2nd paragraph is written provisions do not apply. In this case, the provisions of article 7 shall apply.
5. Âkit State itself, political subdivision, A local authority or a resident of this State gayrimaddî rights paid by the cost of, it will be considered Âkit State is obtained. However, payment of the payer's right gayrimaddî a Âkit a Âkit State whether or not a resident of the State, why pay the rights whose rights or gayrimaddî entity has a connection with a business, or is fixed and the price right office or gayrimaddî fixed sights is installed by the gayrimaddî the cost of rights, including the establishment or fixed place Âkit will be considered obtained in the State.
6. use, rights or amount of paid gayrimaddî the cost of rights information, with a payer and beneficiary, or between both with another person because of the relationship existing between private, in the absence of such a relationship between the payer and the beneficiary exceeds the amount of the actual process, the provisions of this article shall apply only to the most recent mentioned amount. In this case, and any other provision of this agreement in an extra payment, taking into account the State of the legislation will be taxed according to each Âkit.
Article 13 CAPITAL GAINS FROM the INCREASE in VALUE 1. A Âkit located in the State, other State resident Âkit and 6 from the disposal of real estate asset referred to in paragraph provided that other State taxable gains. 2. A Âkit other Âkit of the State-owned State enterprises belongs to securities assets or a workplace Âkit State a resident of the other State, to perform self-employment activities Âkit uses fixed the securities belong gains from the disposal of assets, the establishment (alone or with the whole enterprise) or fixed gain arising from the disposal of the place, including this other State, be taxed.
3. when international traffic run A Âkit State resident aircraft or land transport vehicles or aircraft or land transport vehicles of the operation in question is related to securities gains from the disposal of assets, only in this State would be taxed. 4. paragraphs 1, 2 and 3rd outside of specified in the gains from the disposal of assets only, will be taxed in the State where the resident can dispose Âkit. However, the above mentioned sentence and other Âkit other increase in capital gains obtained in the State, the period between acquisition and disposal does not exceed one year, and other Âkit State vergilendirilebilecektir. Article 14 the SELF-EMPLOYMENT ACTIVITIES 1. A resident of the State, a Âkit independent self-employment activity or the other activities and therefore income, that person in order to perform the activities of other Âkit State can use all the time as long as it's not a fixed place, only this would be taxed in the State. In the case of a person having such a fixed income, attributed to the ground only to be limited to the amount fixed in question, that other State, be taxed.
2. the term "self-employed activities", especially independent scientific, literary, artistic, executed as educational or tutorial activities, as well as doctors, lawyers, engineers, architects, dentists and accountants, independent of the scope of their activities.
Article 15 DEPENDENT ACTIVITIES 1. 16, 18 and 19, without prejudice to the provisions of article Âkit, a resident of the State of a service thus acquired, salary and other similar income, unless other means this service Âkit State only would be taxed in this State. Service means other State, be taxed in the State in this other relevant income obtained from here.
2. irrespective of the provisions of paragraph 1, a resident of the other State a Âkit Âkit a service therefore was the State income, if: a the person who obtained Income, other State-related) calendar year beginning in a twelve-month period or any ending or does not exceed a total of 183 days a a few times as far as I'm concerned, and to other non-residents of State b) payment, an employer is made on behalf of your employer, or by the , and c) payment, the employer's establishment or other State owned fixed place is only the first-mentioned State if not done would be taxed.
3. the provisions of paragraphs 1 and 2 of a resident of the other State regardless of a Âkit Âkit in Exchange for a service that was acquired in the State wages, salaries and other incomes, the expression by people of this service, a resident of the State of a Âkit an undertaking by an aircraft operated in international traffic or land transport vehicles vergilendirilmez other Âkit in realization of this State. Article 16 WE'RE SHUTTING DOWN a resident of the State, A Âkit other PAYMENTS MADE to the Âkit member of the Board of Directors of a company which is a resident of the State due to the acquired pay and other similar payments, that other State, be taxed.
Article 17 ARTISTS and ATHLETES 1. regardless of the provisions of articles 14 and 15, is a resident of a Âkit State Theatre, film, radio or television artist, or a musician, an athlete had personal activities exercised in the other Âkit State hence revenues, this other State, be taxed.
2. An artist or athlete that comes from personal activities exercised, not the artist or sportsman himself another head, this income 7, 14 and 15 of the provisions of articles accepted, depending on the artist or the athlete has been taxed in the State in the activities of Executive Âkit.
Article 18 PENSIONS 1. 1st paragraph of article 19, without prejudice to the provisions on the work of a Âkit State resident of past pensions paid and other similar payments only vergilendirilebilecektir in this State. This provision at the same time, a Âkit State resident interested in regular payment provided for life will be applied.
2. irrespective of the provisions of paragraph 1, within the framework of the social security legislation of the State paid a Âkit pensions and other payments are taxed in this State.
Article 19 PUBLIC SERVICE 1. A Âkit subsection, or the State itself, political a public local administration services provided by a real person in return, this State, section, or other similar charge made by the Administration, salaries and payments, including pensions only vergilendirilebilecektir in this State.
2. A Âkit State itself, political subdivision or local authority in Exchange for commercial activities conducted by linked services, free salary and other similar payments made with pensions 15, 16, 17 and 18 shall apply to the provisions of the article. Article 20 STUDENTS
A Âkit State Âkit State citizen and other vocational training only for the purpose of learning or a student or trainee, for their livelihoods, education or vocational training that other payments from sources other than the State, that other State will not tax it. Article 21 OTHER INCOME of a resident of A Âkit State, no matter where, are not specified in previous articles of this agreement income would be taxed only elements of this State.
PREVENTION of DOUBLE TAXATION article 22 1. Turkey, the double taxation will be avoided in the following manner for resident: a) is a resident of Turkey, (b) in subparagraph grasped revenues according to the provisions of this agreement, excluding vergilendirilebilen acquires an income in Moldova, Turkey will keep that revenue tax-free; But what's left of this person's income when calculating the tax for revenue that exempted tax-exempt, not taking into account the tax rate uygulayabilecektir.
b) A resident of Turkey, article 10, 11 and 12 of this agreement with the 4th paragraph of article 13, according to the vergilendirilebilen acquires an income in Moldova, Turkey, a tax that hit this person's income, equal to the tax paid in Moldova will allow it to offset an amount.
However such offset, offset taxable income in Moldova, shall not exceed the amount of the calculated before tax. 2. Moldova double taxation will be avoided in the following manner for resident: a) is a resident of Moldova according to the provisions of this article in vergilendirilebilen a Turkey, Moldova, this comes from taxes, related to Turkey in mukimin paid an amount equal to the income tax offset will allow it to.
However, in paragraph 2 of this article, mentioned in taxable income attributable to Turkey offset offset in question, calculated before income tax shall not exceed the amount of.
b) if any provision of this agreement when A Moldovan resident according to the income tax in Moldova, Moldova holds the remaining income tax related to this mukimin calculation of exempted income can take into consideration.
FAILURE to DISTINGUISH article 23 1. Citizens of the State, a Âkit other Âkit State, that other State's citizens can remain the same conditions faced by or from, specifically from taxation and that the identity, or in terms of a more severe vergilemeye and due to this, they will not be held subject to the charges.
2. stateless persons who are residents of the State, A Âkit, a Âkit State, the citizens of each respective State we faced in the same circumstances are or may remain in taxation and connected to it from a different or more severe vergilemeye and due to this, they will not be held subject to the charges.
3. the 4th paragraph of article 10, without prejudice to the provisions of a Âkit State işleyeri other Âkit of State-owned enterprises, carrying out the same activities this other State, other State enterprises faced with a taxation less won't lehe.
4. A Âkit State, a resident of the State one or a few other Âkit by, in whole or in part, directly or indirectly, owned or controlled enterprises in the capital, the first-mentioned State, it may be that they are subject to similar enterprises or State taxation or from different or heavier vergilemeye depend on it and they won't be kept subject to tax liabilities connected to it.
5. subsection 1 of article 9, paragraph 7 of article 11, or paragraph 6 of article 12, the provisions of a State to apply, a resident of the other State Âkit State Âkit teşebbüsünce interest paid royalties and other payments, in determining the taxable profits of such enterprise, the first-mentioned State in the same circumstances in which these payments to a resident made downloadable.
6. This provision, a personal or familial status of their resident State Âkit due to tax reductions and personal basis apply discounts also have other Âkit State resident is understanding the application.
Article 24 MUTUAL AGREEMENT PROCEDURE 1. Âkit States a person, one or both of the provisions of this agreement to the process itself that does not create a taxation created or have to, this depends on the application procedure envisaged in domestic legislation of the States, is a resident of the State of the competent authority of the State or State Âkit 23 according to paragraph 1 of the present article falls to the competent authority of the State, is a citizen of Âkit arzedebilir. Such Âkit States when an inquiry must be made within the time specified in the domestic legislation.
2. the competent authority in question, along with finding itself unable to reach a solution satisfactory to justify any objections if, contrary to the agreement in order to avoid a vergilemeyi other Âkit with mutual agreement, the competent authority of the State will make the effort.
3. Âkit States competent authorities, the agreement of all kinds of difficulties resulting from the implementation or by comment or reluctance from the efforts to solve the mutual agreement. Authorities at the same time, not addressed in the agreement resulting from the Elimination of double taxation, for which they can consult each other.
4. Âkit States ' competent authorities, specified in the preceding paragraph to reach an agreement to talk directly with each other in matters directly or from themselves, or they can communicate through a Commission consisting of representatives from.
Article 25 EXCHANGE of INFORMATION 1. Âkit States ' competent authorities, implementation of the terms of this agreement or deal with the information that is required for any discrepancies fall within the scope of the Agreement unless taxes related to the execution of the provisions of domestic legislation subject to change departments shall keep the required information. Any information received by a Âkit State, within the framework of their internal legislation of the State, such as information obtained will be kept confidential and only those incurred or debited of taxes as set forth in the agreement or compulsory execution or punishment and this user and/or complaint and objection jurisdiction to persons or authorities (including judicial authorities and administrative organizations) verilebilecektir. That person or authority such information only in accordance with these purposes. That person or authority such information in court proceedings or judicial decisions can announce when importing. 2. the provisions of paragraph 1, in no way a Âkit State: a State's legislation or Âkit or other) administrative administrative measures to comply with the application;
b) by itself or other Âkit within the framework of the State legislation or normal administrative operations can not be obtained information;
c) secret of any commercial, industrial, professional or commercial operation making information public or is contrary to public order aleniyeti falling under the obligation to provide information cannot be interpreted in such a way.
Article 26 DİPLOMAT HÜVİYETİNDEKİ OFFICERS and CONSULAR OFFICERS 1. The provisions of this agreement, diplomat hüviyetindeki officers or consular officer General rules of international law or of special benefit in accordance with the financial provisions of the agreement will not affect the privileges.
Article 27 ENTERING into FORCE 1. Entry into force of this agreement each Âkit State in its internal legislation to complete other transactions described in Âkit shall notify the State. This agreement will enter into force on the date of receipt of the last of these declarations.
2. the provisions of this agreement: a in terms of the taxes withheld at the source), this year of entry into force of the agreement following the first day of January in the calendar year or later for revenue;
b) income received through the entry into force of this agreement in terms of other taxes that year following the first day of January of the calendar year beginning on or after the taxation year in relation to the provisions for taxes.
Article 28 DON'T WITHDRAWN FROM this agreement will remain in effect until it is terminated in a Âkit by the State. Âkit entry into force of the agreement, each of Us, a five-year period from the date of any calendar year beginning after the expiry of at least six months before the end of the diplomatic channels may terminate the agreement by giving advice of termination. In this case the taxes withheld at the source: a Deal), termination notice is given of the year following the first day of January of the calendar year revenues generated on or after; b) income received through other taxes, given the year of termination notice following the first day of January of the calendar year beginning on or after the taxation year shall take for taxes related to.
These considerations Warrant, the undersigned have signed this agreement, delegates full authority.
Thomas, Moldovan and English languages, all three texts being equally authentic, 25.6.1998, to Kisinev arranged in. In case of discrepancy between the texts the English text shall prevail.
The GOVERNMENT Of The REPUBLIC Of TURKEY On BEHALF Of The GOVERNMENT Of The REPUBLIC Of MOLDOVA On BEHALF Of Ray CHAN PROTOCOL
The Government of the Republic of Turkey, the Government of the Republic of Moldova with double taxation and taxes on Income between the Tax during the signing of the agreement to stop trafficking of the signer are an integral part of the agreement, the following provisions the parties of the agreed.
1.10 in relation to the 3rd paragraph of article, Turkey in terms of dividends, mutual fund and investment trust is understood, including revenues obtained from. 2. in relation to this agreement, the term "capital" means the entity in terms of Moldova.
These considerations warrant, the undersigned duly authorized representatives, signed this Protocol.
Thomas, Moldovan and English languages, all three texts being equally authentic, 25.6.1998, to Kisinev arranged in. In case of discrepancy between the texts the English text shall prevail.
The GOVERNMENT Of The REPUBLIC Of TURKEY On BEHALF Of The GOVERNMENT Of The REPUBLIC Of MOLDOVA On BEHALF Of Ray CHAN
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