Period: 21 Legislative Year: 1 Warning: You Are Viewing Act, The Parliamentary General Assembly Has Already Adopted. If It Does Not Include The Changes Made Later. Income Between The Republic Of Turkey And The Republic Of Croatia

Original Language Title: Dönem : 21 Yasama Yılı : 1 Uyarı: Görüntülemekte olduğunuz Kanun, TBMM Genel Kurulunda kabul edildiği halidir. Varsa daha sonra yapılan değişiklikleri içermemektedir. TÜRKİYE CUMHURİYETİ İLE HIRVATİSTAN CUMHURİYETİ ARASINDA GELİR

Read the untranslated law here: https://www.tbmm.gov.tr/kanunlar/k4525.html

Law No. 4525 Acceptance date: 1.2.2000
Article 1 - September 22, 1997, signed in Zagreb "Double Taxation Agreement Between the Republic of Turkey and the Republic of Croatia on Income Taxes" and found the appropriate approval of the additional protocol. Article 2 - This Law shall enter into force on the date of publication. Article 3 - This Law shall be enforced by the Council of Ministers.

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

REPUBLIC OF TURKEY
AND
REPUBLIC OF CROATIA
Desiring to a tax on income in the agreement to prevent double taxation
HAVE AGREED THE FOLLOWING:
ARTICLE 1
SCOPE PEOPLE
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Article 2
TAXES COVERED
1. This Agreement, irrespective of the manner in shall apply to taxes on income in a Contracting State or local administrations.
2. Securities or fees with taxes on gains from the alienation of immovable property or by undertakings of the total amount of the salary, including taxes paid, total income or any tax on income elements will be considered taxes on income. 3. The taxes that apply at the moment to implement this Agreement:
a) in Turkey:
i) the income tax;
ii) the corporation tax; and
iii) the levy imposed on the income tax and corporation tax;
(Hereinafter referred to as "Turkish tax" will be mentioned)
b) Croatia:
i) the profit tax; and
ii) the income tax;
(Hereinafter referred to as "Croatian tax" will be mentioned).
4. The Agreement also after the date of signature of the Agreement in addition to or in place of their existing taxes and that the same quality as existing taxes or shall apply also to substantially similar taxes. The competent authorities of the Contracting States shall notify each other of any significant changes made in their respective taxation laws.
Article 3
GENERAL DESCRIPTION
1. For the purposes of this Agreement, unless the context otherwise defined therein shall:
a) i) the term "Turkey" Turkey's is the sovereignty, territorial sea, territorial waters, but also to investigate the natural resources in accordance with international law, exploitation and conservation of jurisdiction with the purpose or refers to that sea area has a sovereign right;
ii) the "Croatia", the term sovereignty of the owned by the Republic of Croatia, the territorial sea, as well as the study of natural resources in accordance with international law, exploitation and conservation of jurisdiction with the purpose or refers to that sea area has a sovereign right;
b) The terms "a Contracting State" and "the other Contracting State", as required by the text mean Turkey or Croatia;
c) the term "tax" of this Agreement in Article 2 refers to the understanding of any tax;
d) the term "person" includes an individual, a company and any other body of persons within the scope of persons;
e) The term "company" to mean any entity that is treated as any institution or corporate for tax purposes;
f) The term "national" means:
i) any individual possessing the nationality of a Contracting State;
ii) any juridical status by winning the laws in force in a Contracting State personal, partnership or association
It refers.
g) "a Contracting State" and "other Contracting State" mean, respectively, owned by a resident of the other Contracting State and an enterprise operated by a resident of a Contracting State means an enterprise;
h) "competent authority" means:
i) The case of Turkey, the Minister of Finance or his authorized representative; and
ii) in the direction of Croatia, the Minister of Finance or his authorized representative
means;
i) "International traffic" by a Turkish or Croatian undertakings only ship made between places in the territory of Turkey or Croatia, with the exception of aircraft or road vehicles for transport, ship, express transport aircraft or road vehicles operated.

2 by a Contracting State of the Agreement on the implementation at any time, any term not defined therein shall, unless the context otherwise defined therein shall, for the purposes of the tax will be applied footer of roll, that date will have the meaning that it has in the State's legislation, contained in the Government's current tax legislation in a sense, other legislation of that State shall take precedence over the meaning given to that term. Article 4
RESIDENT
1. For the purposes of this Agreement, "a Contracting State to a resident" refers to that State or local administrations is de içermeket, the other state's legislation in accordance home, habitual residence, legal head office, place of management or similar structure with the taxpayer because of any other criterion person means. However, this term only because taxable income derived from sources in that State does not include any person.
2. thus the provisions of paragraph 1 an individual is both Contracting States the resident status of the person shall be determined as follows: a) the individual shall be deemed a resident of the State in which a dwelling may be permanent. If a person's residence can accommodate both the State as well as permanent, this is personal and that closer economic relations (center of vital interests) shall be deemed to be a resident of the State; b) If the person's center of vital interests is contained by the state determined, or at either State or a residence can be permanent, he shall be deemed to State a resident of the house where the habit to remain;
c) If the person has a habit of staying at home in both States or both of the State in such a house is not a concern, then it shall be deemed to be a resident of Delvet vatndaş;
d) if he is a citizen of both States or not the citizens of both States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
3. Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting State in that person, shall be deemed to be a resident only of the State in which the place of effective management is located.
Article 5
WORKPLACE
1. For the purposes of this Agreement, "permanent establishment" means a fixed place of business is wholly or partly carried out the work of an enterprise.
2. "Housing" refers in particular to encompass the following:
a) a place of management;
b) Branch;
c) The Bureau;
d) Plant;
e) a workshop, and
f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. 3. "Office" means the addition of this:
a) a building site continue for a period of more than twelve months, construction, installation or facility or supervision of the project;
b) take the time to the ongoing and attempts by employees or other related personnel via consultation with the other Contracting services provided by the State, including in excess of a total of 12 months for the same or related project of a Contracting State coverage.
4. Notwithstanding the preceding provisions of this Article, the "permanent establishment" shall be deemed to include the following points:
a) the maintenance of facilities, only the storage of goods or merchandise belonging to the enterprise, is used for the purposes of display or delivery;
b) the maintenance of a stock of goods or merchandise only storage, display or delivery of retention;
c) the maintenance of a stock of goods or merchandise, solely for the purpose of processing by another enterprise;
d) for a fixed place of work, the only attempt to purchase goods or merchandise or held for collection of information;
e) for a fixed place of work, with only a preparatory or auxiliary character for the enterprise, held for the conduct of any other business;
f) a fixed place of work for only a) to e) is held together to perform one or more of the activities mentioned in subparagraphs; but it is essential that the overall activity of a preparatory or auxiliary character as a result of the execution of these activities together.

5. 1st and 2nd paragraph of notwithstanding the provisions, a person -6 th except in a Contracting State an agent of an independent status to apply the clause, is acting on behalf of an enterprise and has, and the name of the enterprise contract conclude agreements, if it uses this authority usually, these unless the person's activities are limited to those mentioned in paragraph 4, these undertakings, in respect of any activities carried out by that person will be accepted for the enterprise has a permanent establishment in that State. However, the activities carried out through a fixed place of business within the framework of the aforementioned paragraph, would not make this place a workplace. 6. A Contracting State only the other Contracting State in the business, a broker who in the ordinary course of their business, general commission agent or independent status, carried out by any other agency shall be deemed to have a permanent establishment in that other State.
7. A company which is a resident of a Contracting State in the other Contracting States which controls or controls a company which carries on business in that other State, or if controlled by him (whether through a permanent establishment or otherwise), any of the company a permanent establishment of the other It will create.
Article 6

THE INCOME OBTAINED FROM REAL ESTATE ASSETS 1. Income derived from immovable property situated in the other Contracting State a resident of a Contracting State (including income from agriculture or forestry) may be taxed in that other State.
2. "immovable property", the term shall be defined according to the legislation of the Contracting State in which the assets. Terms in any case, property accessory to immovable property, agriculture and vehicles used in agriculture and forestry, rights related to real estate property will be applied to private law, real estate usufruct rights and mineral deposits, sources and other natural resources at an operation or operating rights arising from fixed or on variable payments including rights; ships, aircraft and road vehicles shall not be regarded as immovable property.
3. The provisions of paragraph 1, the direct use of immovable property shall apply to income derived from the letting or use in any other form. 4. The provisions of paragraphs 1 and 3 paragraphs at the same time, an enterprise and to income derived from immovable property used for the performance of independent personal services shall also apply to income derived from real estate assets.
ARTICLE 7
BUSINESS PROFITS
1. The profits of an enterprise of a Contracting State, unless there is commercial activity such enterprise through a permanent establishment located in the other Contracting State shall be taxable only in that State. If the enterprise carries on business as aforesaid, the profits of such other State, be taxed only to be limited to the amount attributable to that permanent establishment. 2. paragraph 3 shall, without prejudice to, when a Contracting State on business through a permanent establishment contained in the other Contracting State, each Contracting State in this work, if this work under the same or similar circumstances, located in the same or similar activities, fully If a separate and independent undertakings and undertakings which had won completely independent from nature create a workplace that is what earnings will be attributed to a gain of the same amount.
3. In determining the profits of a permanent establishment, made in the State in which the permanent establishment is situated, or in any other place, the area covered by the general management and administration expenses, the aim will be allowed to work in a reduction of the corresponding expenses.
4. Office of the mere purchase of goods or merchandise for the enterprise business will therefore by no attributable profit.
5. Gain receives the scope of income elements arranged separately in other Articles of this Agreement, the provisions of those Articles shall not be affected by the provisions of this Article.
ARTICLE 8
INTERNATIONAL TRANSPORT
1. In international traffic of a Contracting State, the ship gains accruing from the operation of aircraft or road vehicles shall be taxable only in that State.
2. For the purposes of this article, vessel, aircraft or land vehicles of the profits derived from the operation in international traffic: a) in international traffic, ships, aircraft or equipped or gains derived as incidental to the bare rental of land vehicles;

b) Containers (including related equipment and attractive container transportation) from the use of, or in terms of earnings derived from the leased
It would include.
However, such rental, use or maintenance of ships in international traffic, the operation of aircraft or road vehicles is required in addition to or as an incidental activity.
3. The provisions of paragraph 1 of this Article shall also be implemented in partnership with a joint business or international operating agency to profits from the participation.
Article 9
ASSOCIATED ENTERPRISES
1. a) a Contracting State participates directly or indirectly in the management of the other Contracting State, when he joined, control or capital, or
b) the same persons participate directly or indirectly by a Contracting State of the other Contracting State the management, control or capital attended,
and in either case, that occur in commercial or financial relations between the two undertakings or imposed conditions when differ from those which would be made between independent enterprises, it should be in one of these undertakings, but these conditions due to the accrued, may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise and taxes accordingly taxed in the other Contracting State in the other Contracting State may include one of the enterprises gain. At the same time, earnings are by the first-mentioned Contracting State, not reported earnings, the relationship will be made between independent enterprises, keeping in mind, the first-mentioned Contracting State subsequently carried out by calculation may be determined as a result of earnings. When such a situation manifested itself, shall make an appropriate adjustment to the amount of tax on the profits of the other State concerned. This adjustment, the other provisions of this Agreement shall consult each other to be kept in mind and the competent authorities of the Contracting States when required. ARTICLE 10
DIVIDENDS
1. Dividends paid to a resident of the other Contracting State by a company which is a resident of a Contracting State may be taxed in that other State.
2. However, such dividends may be taxable in the company paying the dividends is a resident of that Contracting State and according to the laws of that State; but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10% of the gross amount of the dividends in all cases.
3. This article is used in "dividends" means income from shares, the dividend shares or jouissance rights, according to the founders' shares or debt-claims of not earning join will provide you with the income obtained from other rights distribution companies of the State of legislation that resident, obtained from the shares for tax purposes the same is treated as income from other companies obtained the rights to income mutual funds and investment trusts refers to income.
4. A Contracting State company earnings available commercially through a permanent establishment contained in the other Contracting State, after having been taxed according to this establishment for the Contracting State in Article 7, the remainder over 2 of this Article be taxed in accordance with paragraph. 5. The dividend beneficiary is a Contracting State, if the dividend-paying company is resident is where the commercial faatliyet through a permanent establishment contained in the other Contracting State or a resident of Turkey, is found in self-employed activities through quite a bit hard place in Croatia and the dividend is concerned with the events of acquiring it It is effectively a link between the permanent establishment or fixed place, and paragraph 2 of Article 1 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.
ARTICLE 11
INTEREST
1. Born in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State.
2. However, such interest may also be taxed in the Contracting was obtained by the State and that State's legislation; However, if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.
3. When used in this article, "interest" means, whether or not connected to the mortgage guarantee or borrower you know will recognize the right to share the profits, income arising from claims of every kind, and especially public income derived from securities and bonds and equities, as well as the question of the securities, the bonds and bills for premiums and bonuses represent.

4 real interest beneficiary is a Contracting State, if no commercial activity by the other Contracting State in quite a bit of a workplace that results in interest or a resident of Turkey, is found in self-employed activities through quite a bit hard place in Croatia and said that the workplace receivables payment of interest or It is effectively a link between fixed locations, paragraphs 1 and paragraph 2 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.
5. A Contracting State itself, a local authority or the interest paid by a resident of that State, he shall be deemed to arise in the Contracting State. However, the person paying the interest, whether a Contracting State to a resident or not, has in a Contracting State interest is paid to the cause of the indebtedness with a permanent establishment or fixed base in connection with the relationship and interest is borne by such permanent establishment or fixed base, then such interest, establishment or fixed the Contracting State in which it is located shall be deemed to arise.
6. The amount of interest paid in exchange for receivables from real beneficiaries payer or because of a special relationship with any other person with both, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such a relationship, provisions of this Article shall apply only to the last-mentioned amount. In this case, an additional payment, taking into consideration other provisions of this Agreement shall be taxable according to the laws of each Contracting State.
ARTICLE 12
GAYRİMADDÎ ROYALTIES
1. Born in a Contracting State and paid to a resident of the other Contracting State gayrimaddî royalties, it may be taxed in that other State.
2. However, in the present Contracting State in which they arise and that gayrimaddî royalties taxed by the state legislation; however, gayrimaddî if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties gayrimaddî.
3. When used in this article, "gayrimaddî royalties" includes films and literary works, including radio and tapes used in the television broadcast, the right to artistic or scientific work of others, of any patent, trade mark, design or model, plan, secret formula or methods of production or industrial, commercial or scientific experience or knowledge of industrial, covers all types of payments made in exchange for the use or right of use of commercial or scientific equipment.
4. the beneficial owner of gayrimaddî royalties is a Contracting State, if no commercial activities through quite a bit of a permanent establishment in the other Contracting State in which he obtained such price or a Turkey resident is found in self-employed activities through quite a bit hard place in Croatia and the said fee paid right or property and is effectively a link between such permanent establishment or fixed base, paragraphs 1 and paragraph 2 of this Article shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.
5. A Contracting State itself, a local authority or of the gayrimaddî royalties paid by a resident of that State, he shall be deemed to arise in the Contracting State. However, the person paying the gayrimaddî royalties, whether a Contracting State to a resident or not, is in a Contracting State gayrimaddî royalties to pay Why have a permanent establishment or fixed base in connection with the rights or assets and when gayrimaddî royalties are borne by such permanent establishment or fixed base, gayrimaddî of such royalties shall be deemed permanent establishment or fixed base is obtained in the Contracting States.
6. Use the amount of gayrimaddî royalties paid in exchange for right or information between the beneficial owner and the payer, or because there is a legal relationship with any other person with both, exceeds the amount which would have been agreed between the beneficial owner and the payer in the absence of such relationship, the provisions of Article It shall apply only to the last-mentioned amount. In this case, an additional payment, taking into consideration other provisions of this Agreement shall be taxable according to the laws of each Contracting State.
ARTICLE 13
CAPITAL GAINS
1. Mukîmîne of a Contracting State in the other Contracting State and contained in Article 6 of the gains from the alienation of immovable property referred to in the article, may be taxed in that other State.

2. A Contracting State of the disposal of a fixed place of immobile assets that other Contracting State-owned movable property of a permanent establishment or a Contracting State a resident of the other Contracting State independent personal services uses to perform Gains, this establishment (alone or with the whole enterprise together ) or including gains from the disposal of fixed base, may be taxed in that other State.
3. A Contracting State Mukîmîne of ships operated in international traffic, aircraft or road vehicles or such ships or aircraft derived from the alienation of movable property pertaining to the operation of transport means the gains shall be taxable only in that State.
4. 1, 2 and 3 in paragraphs gains from the alienation of any property other than those specified, shall be taxable only in the Contracting State of which he is a resident of the disposal of.
ARTICLE 14
Independent Personal Services
1 of a Contracting State residents, self-employed activity or income derived by other activities of an independent character, that person unless there is a fixed constant that can be used locations in order to perform their activities in the other Contracting State shall be taxable only in that State. A person's income when it has such a fixed base, only to be limited to the amount attributable to that fixed in question, may be taxed in that other State.
2. "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities, as well as the doctors, lawyers, engineers, architects, dentists and the independent activities of accountants.
ARTICLE 15
ASSOCIATED ACTIVITIES
1. 16, 18, 19, and without prejudice to the provisions of Article 20, a service therefore wages earned in a Contracting State a resident of wages and other similar remuneration, that unless the employment is exercised in the other Contracting State shall be taxable only in that State. If the services are rendered in that other State, the said income derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, a resident of the Contracting State where the income received in respect of an employment exercised in the other Contracting State if:
a) persons who generate revenue, the other States in the beginning of the calendar year or any twelve-month period ending in one or a few times if the total not to exceed 183 days, and
b) Payment, if the other State by a non-resident employer or on behalf of an employer, and
c) the remuneration, the employer has in the other State or a permanent establishment which is not borne by a fixed place
It shall be taxable only in the first-mentioned State. 3. This item previous provisions, regardless of an aircraft operated in international traffic of ships or road vehicles in the performance of the service thus obtained salaries, wages and other similar remuneration enterprise resident that Contracting State may be taxed. ARTICLE 16
MADE PAYMENTS TO DIRECTORS
1. resident of a Contracting State, a resident of the other Contracting State that fees charged by the company's board members and other similar remuneration derived by a couple, may be taxed in that other State.
ARTICLE 17
ARTISTS AND SPORTSMEN
1. 14 and notwithstanding the provisions of Article 15, a Contracting State a theater, motion picture, radio or television artist, a musician or an athlete in the other Contracting State exercised in the income from his personal activities of this nature, that other State may be taxed.
2. When an artist or income in respect of personal activities as athletes exercised not to the entertainer or sportsman himself but to another person, that income 7, 14 and bound by the provisions of Article 15 notwithstanding the artist or taxed in the Contracting State in which the performance of the athlete's activities.
ARTICLE 18
PENSIONS
Article 19 1. Without prejudice to the provisions of paragraph 1, pensions and other similar remuneration paid in consideration of past employment to a resident of a Contracting State shall be taxable only in that State.
ARTICLE 19
GOVERNMENT SERVICE
1. therefore a public task to a Contracting State itself or local administrations in respect of services rendered by an individual, charges made by the government or the administration, wages and other similar remuneration, including pensions shall be taxable only in that State.

2. A Contracting State or a local authority in return for services rendered in connection with commercial activities conducted by salaries, wages and other similar remuneration and pensions of 15, 16, 17 and Article 18 shall apply.
ARTICLE 20
TEACHERS AND STUDENTS
1. The nationals of a Contracting State in the other Contracting State solely for subsistence to a student or apprentice who is the purpose of education or vocational training, for education or vocational training costs, payments from sources outside that other State may not be taxed in that other State. 2. In the same way, is a Contracting State of the citizens of the other Contracting State solely for teaching or a teacher's money teaching or research for a period or periods not exceeding two years in which to make scientific research, and income derived from sources outside that other State, from tax in that other State It shall be exempt.
3. The nationals of a Contracting State in the other Contracting State education or to gain practical experience related to the profession, a calendar year in performing services not to exceed 183 days a student or fees derived by the trainees, shall not be taxed in that other State. 4. For the purposes of paragraph 2 of this article, "Teacher" means faculty includes professors and other individuals with similar academic title.
ARTICLE 21
OTHER INCOME
1. resident of a Contracting State, where you were born is born, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
2. Article 6 of the 2 nd, except for income derived from immovable property as defined in paragraph, a Contracting State which said the recipient of such income in that other Contracting State injured if no commercial activities through a permanent establishment or in that other State independent personal services through quite a bit hard place If and with no such right or property is effectively a link between such permanent establishment or fixed base, the income to the provisions of paragraph 1 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.
ARTICLE 22
ELIMINATION OF DOUBLE TAXATION
1. Double taxation for residents of Turkey shall be eliminated as follows:
a) Where a resident of Turkey, (b), except for income grasped in me, according to the provisions of this Agreement when they earn an income taxable in Croatia, Turkey will be exempt from the income tax; however, be able to apply a tax rate, taking into account such person as calculating tax on the remaining income was not exempt from income tax.
b) Where a resident of Turkey, this Agreement 10, 11 and when Article 12 according derives income which may be taxed in Croatia, Turkey, from the tax on the income of that person, shall allow a deduction of an amount equal to the tax paid in Croatia. However, such deduction to taxable income in Croatia shall not exceed the amount of tax computed before the deduction.
2. A Croatian resident, when they have an income that can be taxed in Turkey in accordance with this Agreement, Croatia, an amount equal to the tax paid on income in Turkey through direct right or discount will be deducted from the tax on the income of that resident. However, such deduction, calculated before the deduction of income tax attributable to the income which shall not exceed the amount in Turkey.
Article 23
NON-DISCRIMINATION
1. A Contracting State citizens of the other Contracting State, that other State of the citizens in the same circumstances to any taxation staying or face and the associated liabilities, especially in terms of residency will be subject to different or more burdensome than the taxation and related obligations. This provision shall, notwithstanding the provisions of the first substance, a State or in either State shall also apply to persons who are not resident.
2. A business owned enterprise of a Contracting State in the other Contracting State, that other Contracting State less favorably compared to an undertaking carrying on the same activities will remain a tax levied.

3. A Contracting State by the other Contracting State one or more residents, directly or indirectly, totally or partially owned capital or controlled enterprises, in the first-mentioned State, olabilecekter they are or subject to other similar enterprises of the State taxation or any requirement related obligations or more will be subject to heavy taxation and related obligations.
4. Article 9 paragraph 1 of Article 11 paragraph 6 or Article 12 of the 6th paragraph, except for situations where application of the provisions of a Contracting State enterprise of the other Contracting State Royalties paid to a resident of royalties and other payments, such taxable enterprise in determining the gain, be deductible as if made to a resident of the first-mentioned State in the same circumstances.
5. These provisions, a Contracting State to a resident of his own personal allowances due to personal or family circumstances apply, exemptions and discounts on base will also have to be understood in terms of the other Contracting State resident.
ARTICLE 24
MUTUAL AGREEMENT PROCEDURE
1. A Contracting State, when it reached the conclusion Contracting State where one or both of the procedures of taxation created or will not fall in accordance with the provisions of this Agreement for itself, this State of the remedies provided by the domestic legislation without the status of the competent authority or the state of the Contracting State is a resident of the 23th If the substance falls according to paragraph 1, where citizens of the Contracting State of which the competent authority. The case, following the notification taxation contrary to the provisions of this Agreement must be made within three years.
2. The competent authority shall endeavor, if the objection is justified if it can not reach a satisfactory solution, in order to prevent a taxation contrary to the agreement, it will endeavor to mutual agreement with the competent authority of the other Contracting State.
3. The competent authorities of the Contracting States, any difficulties or doubts arising as to the interpretation or application of this Agreement shall endeavor to resolve by mutual agreement. The authorities at the same time, resulting in cases not provided for in the Agreement may also consult together for the elimination of double taxation.
4. The competent authorities of the Contracting States may communicate directly with each other to reach agreement on the issues specified in the preceding paragraph. When the verbal exchange of views is deemed necessary for reaching an agreement, these negotiations may be conducted through a Commission consisting of representatives of the competent authorities of the Contracting States. ARTICLE 25
EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States, as long as the mismatch with the knowledge or agreement necessary for the implementation of the provisions of this Agreement, the information will hold subject to changes that are necessary for the implementation of domestic legislation on taxes covered by the Agreement. Any information received by a Contracting State, that State of the information obtained under the domestic legislation will be kept confidential and as such, but only with the assessment or collection or enforcement or punishment of the tax specified in this Agreement and deal with complaints in these matters and appeals officers persons or authorities (judicial authorities and including administrative bodies) can be given. Such persons or authorities shall use such information only for such purposes. These persons or authorities may disclose the information in public court proceedings or in judicial decisions. 2. The provisions of paragraph 1, a Contracting State by any means:
a) to carry out administrative measures at variance with that or the other Contracting State legislation and administrative practice;
b) legislation that or the other Contracting State or to supply information which is not obtainable under the normal administrative procedures;
c) Any commercial, industrial, or professional secret or trade process, which makes public information or publicity can not be interpreted to be put under the obligation to falling contrary to public order.
ARTICLE 26

IDENTITY OF DIPLOMATIC MISSIONS And consular officers
1. The provisions of this Agreement, under the general rules of international law or the provisions of special agreements of diplomatic agents or consular officers shall affect the fiscal privileges.
ARTICLE 27
ENTRY INTO FORCE

1. Each Contracting State for the entry into force of this Agreement the completion of the procedures required by its domestic legislation, shall notify the other Contracting State. This Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of this Agreement:
a) in respect of taxes withheld at source, on the first day of January in the calendar year following the date of entry into force of this Agreement or for amounts paid or credited on later;
b) in respect of other taxes, on the first day of January in the calendar year following the date of entry into force of this Agreement or shall apply to taxable years beginning then.
ARTICLE 28
Termination
This Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Agreement by giving notice of termination through diplomatic channels at least six months before the end of which the Agreement enters into force from the date after the expiry of a period of five years starting in any calendar year. In this case the Agreement:
a) in respect of taxes withheld at source, for amounts paid or credited after the end of the calendar year in which the notice is given; b) in respect of other taxes, after the end of the calendar year in which the notice is given to taxable years beginning
The provisions will not be expressed.
The confirmation of this matter, whereof the undersigned, duly authorized, have signed this Agreement.
in duplicate in Zagreb it was organized on September 22, 1997, in the English language.
ON BEHALF OF THE REPUBLIC OF TURKEY ON BEHALF OF THE REPUBLIC OF CROATIA Ray ÇELEBİ Borislav SKEGRO
PROTOCOL
Taxes on Income between the Republic of Turkey and the Republic of Croatia during the signing of the Double Taxation Agreement, the signatory parties have agreed that in respect of the following provisions constitute an integral part of the Agreement.
1. With respect to Article 22 paragraph 1
The offset direction mentioned in this paragraph, for the first five years following the date of entry into force of this Agreement:
a) paragraph 2 of Article 10 of that paid 10% tax on the dividends mentioned b) of paragraph 2 of Article 11, which is paid 10% tax on interest on said
It will be accepted.
2. With respect to Article 25 paragraph 2 of the
Refunds arising from the mutual agreement of the taxpayer, the taxpayer is understood that after the report referred to the Tax Office said the result had to request mutual agreement within a year.
The confirmation of this matter, whereof the undersigned, duly authorized, have signed this Protocol.
in duplicate in Zagreb it was organized on September 22, 1997, in the English language.

ON BEHALF OF THE REPUBLIC OF TURKEY ON BEHALF OF THE REPUBLIC OF CROATIA Ray ÇELEBİ Borislav SKEGRO