Key Benefits:
PREVENTING AND PREVENTING OUTPUT FROM DATA FROM THE TURKISH REPUBLIC TO THE PORTUGUESE REPUBLIC, THE LAW TO PREVENT TRAFFICKING AND THE APPROVAL OF THE ECHO PROTOCOL ARE APPROPRIATE.
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Kanun No. 5515 |
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Date of Admission: 1/6/2006 |
MADDE 1- 11 Mayis 2005 The "Agreement between the Republic of Turkey and the Republic of Portugal in the Land of the Republic of Portugal on the Prevention of Preventing Double Taxation and Preventing Tax Evasion" is appropriate for the approval of the "Protocol on the Prevention of Preventing Double Taxation and Preventing Tax Evasion between the Republic of Turkey and the Republic of Portugal."
ARTICLE 2- On the release date of this Law It will take effect.
TICAD 3- The Council of Ministers executes the provisions of this Law.
REPUBLIC OF TURKEY PORTUGAL REPUBLIC
RECEIVED ON ARRIVAL
PREVENTING AND PREVENTING OUTPUT FROM DATA VERGID
OBSTRUCTION OF TRAFFICKING
UNDERSTANDING
REPUBLIC OF TURKEY
ILE
REPUBLIC OF PORTUGAL
Tax revenue over Revenue with the desire to make a statement that prevents double taxation and prevents tax evasion
ADD TO FEBRUARY MEANING:
SECTION OF THE REGION SECTION
SCOPE OF UNDERSTANDING
CAPACITY COVERED
This means that one or both of the Skit States will have a meeting. will be applied to the system.
Article 2
POWER-OFF DATA
1. This information will apply to taxes on behalf of a State, political or administrative subdivision or neighborhood administrations, regardless of how much it has been taken.
2. Total taxes, including taxes levied by taxes and fees imposed on earnings from the transfer of real estate or real estate entities, including taxes levied on capital, including taxes on a total amount of income, or all taxes received over the elements of income, will be considered as tax from income.
3. Specifically, taxes that apply to the deal are applicable:
a) from Portugal:
i) personal income tax (Imposto sobre o Rendenmento das Pessoas Singullares -IRS);
ii) agency income tax (Imposto sobre o Rendenmento das Pessoas Colectivas- IRS);
iii) additional neighborhood tax on corporate income tax (Derrema);
(This will refer to as "Portuguese tax").
b) In the direction of Turkey:
i) income tax;
ii) corporate tax;
iii) the share of funds received over income tax and corporate tax;
(This will refer to as "Turkish tax");
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 report to each other the important depositions made in the tax legislation.
REGION OF A REGION
DEFINITIONS
Clause 3
GENERAL DEFINITIONS
1. From the purposes of this task, unless the text is predicted to the contrary:
a) The term "Portugal" is a Portuguese territory, its territorial waters, and the Refers to the areas of the Portuguese Republic that are used in accordance with the international law, jurisdiction, protection, and protection of the rights of the judiciary, or the areas of sovereignty used in accordance with the international law;
b) "Turkey", its territory, its territorial waters, its response. The jurisdiction of Turkey's jurisdiction or sovereignty rights in order to search, operate, and protect the relevant resources in accordance with international law, and the areas of sovereignty used;
c) The terms "A State" and "Secretary of State", according to the text of the text, Refers to Portugal or Turkey;
d) the term "Kishi" is a real match, a company, and a business. includes any installation;
e) the term "February" as an institution in any form of institution or taxation. to any installation that is being treated;
”f) "The contact of the State of a Kite State" and "the contact of the other Akite State" with the terms of the terms, a service that is being pushed by the machine of a Instrument State, and a contact that is being pushed out by the team of the Diaper Devlet Devlet;g) The term "internationalistic traffic" is only the left of the other Skit State. statements made by the State of the Republic, including the ship, aircraft or land transmission, except for the fact that the ship, aircraft or land transmission is not to be committed, has been reported.
h) "Authority for authority":
(i) in Portugal: Finance Minister, Taxation Directorate
(Director Geral dos Impostos) or their authorized representatives;
(ii) in Turkey: the Finance Minister or its authorized representative;
refers to.
i) The term "Citizen":
(i) any real person who has a citizen of a Akkit State;
(ii) any status that makes a status according to the legislation that is in effect in a Akite State a legal entity, a partner, or association
refers to.
2. As an understanding of the implementation at any date by the State, any term not defined herein is subject to the purposes of this state, at the time of the purposes of the purposes of the tax, unless the text is foreseen to be contrary to the text. The meaning of this state in the current tax course will have a superiority over the meaning of this state in the current tax course.
Clause 4
MUKOM
1. For the purposes of this statement, the term "a Instrument State" is a state, including any political or administrative subdivision or neighborhood administration, and that state is subject to the legislation, residence, residence, the main center, the administration place, or the In a similar structure, it means the taxpayer, which is the taxpayer, because of any criteria. However, this term does not include any money that is being subject to tax due to income from sources in that State alone.
2. The state of the following will be determined in the case of the first of the 1st storm provisions, as well as the actual performance of both Sat Devices:
a) This is the state of the state where a home is only permanent. Will be accepted. If there is a home in which both Develes remain permanently, it will be regarded as the muchas of the state, where only their personal and economic relations are closer (the centre of vital interest);
b) State of the center of the vital interests of the Euca. if it cannot be determined, or if there is no permanent home in both Devlette, it will be accepted to the purpose of the Âkit State, where the home is not the only one that has left the place;
c) If there is a home in which the Eyer is found to remain in both of the Azoys. or if such a house is mentioned in both Devlette, only the government of the state of which it is a citizen will be accepted;
d) Both Devlets are citizens of both State or both State If it is a citizen, the authorities will resolve the issue of the authorities in the case of the authorities.
3. A part of the real part of this material, in which both Azite Deletions are consents, will only be considered to be the party of the effective administration in which the effective administrative location is found. However, if the active management location of this winter cannot be determined, The competent authorities of the State States will be able to determine which state of this task is considered to be considered as a part of the purpose of this statement.
Clause 5
ISRAELÝÞYERÝ
1. For the purposes of this, the term "workplace" refers to a fixed place where the business of a private business is fully or completely executed.
2. The term "workplace" is specifically included in the following:
Yönetima) Management location;b) Feb;
c) Bureau;
d) Factory;
e) Workshop, and
f) Maden oasis, oil or natural gas well, hot water or natural gas Any location where resources are grapeed.
3. An ongoing construction, construction, assembly or installation project, or surveillance activities related to a nine-month period of time, will be a place of office.
4. Any prior provisions of this clause will be considered to include the term "workplace":
a) The resources of the relationship, property of the business or business of the business be used only for storage, purpose, or delivery purposes;
b) Only storage, technical, or commercial stocks of the country belonging to the country. or, for delivery purposes;
c) Stock-related goods or commercial stocks, only one bareka To be achieved with the purpose of being pushed to the country;
d) sell business to business or business only if a fixed location is retention, or collecting information;
e) prepared only for the operation of a stable site with the purpose of executing any other character, such as the execution of any other person;
f) A fixed location is mentioned only in (a) to (e) to execute a few of the activities together; however, it is important to prepare or help the activity that is a result of the execution of all of these activities in fixed sites.
5. In an event where the provisions of the 1st and 2nd fests were removed, a team of two and a half of the world's remains were identified as if they were to act on behalf of a government, if the State of America acted on behalf of the state of a country. The first mentioned in the Âkit Devlette will be accepted with a location:
a) This is the person who has the authority to fend off contact with the state of the state. And if using this authority from the mutaden, the company's activities are in place of office, as it does not have any activities identified in the 4th frame from a fixed location, which would not place the place in place, according to the current state of the fund. will be accepted.
b) This is an orderly, a regular bus, not authorized to have such authority. If any of the activities that were originally shipped from goods or business were found in the Devlette mutaden property or commercial, and any activities that will contribute to the sale of the goods or business, the site will be deemed to have been found.
6. A public bus, a Sitel Devlette, has a business in this state, as it conducts its business in a state of emergency, general commission agency, or any agency that has the status of any other agency in the status of the state. It will not be.
7. A company that is a member of the State of a âite, a member of the Devilitet State, or a company that is engaged in commercial activity in this state, or if it is controlled by it, is controlled by the company. Each one will not have an office space for the other.
THIRD PART
UNDUE DATA
Clause 6
OBTAINED FROM GEYRISECURITIES GELIR
1. Income from real estate, which is in the case of a Profit State, is taxable (including income from agriculture or forestry), and it may be taxed in this other State.
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 real estate, real estate owned by real estate assets and livestock, and livestock, private law provisions, which are used in the forest, including its subsequent assets and livestock. It will cover the rights of the Intifa rights and mines, resources and land supply, whether they are fixed or stable; ships, planes, and land transfer vastatics are in real estate. does not have to be accepted.
3. The 1st fikra provisions will be applied to the revenue generated from the use of real estate, leased or otherwise used in any other way.
4. The 1st and 3rd fikra provisions will also be applied to the revenue generated from real estate assets and real estate assets used in the real estate assets of a private estate.
Clause 7
FINANCIAL GAINS
1. The benefit of a Turkish government is that it will be taxed only in this state, as it is not in commercial activity there, with a location in the office of the teleport, Akit Devlette, and the other. If commercial activity is found in the above mentioned commercial activity, the earnings of the country may be taxed in the other state, only to be left with the amount that can be attributed to this business.
2. In the event of commercial activity there, both in the Azoit Devlette were the same or similar conditions that would be attributed to the site, as the 3rd fikra provisions were held there by a site of the state's office in a State of the Republic of Azite, in the event of a State of the Republic of Azite. It would be a different kind of gain, regardless of whether it would be a fully qualified person, with a separation of the same or similar activities, and a qualification that would have been completely different from the person who had been involved in the event.
3. When determining a location, you will be allowed to download expenses that are appropriate for the purposes of the site, including management and general administration expenses, that are located on the site of the state or state where the location is located.
4. Instead, no gain will be attributed to the purchase of goods or commercial services by this location alone, only if the service is received.
5. The provisions of this provision will not be affected by the provisions of this clause, as the benefit includes elements of income that are organized separately in other items of this statement.
Article 8
SHIP, AIR, AND LAND TAXABLE
1. The gains from the government of a Akite State campaign to transport ships, aircraft or land transport in international traffic will be taxed only in this state.
2. The 1st frikra provisions will also be applied to a partner, a partner, a partner or an agency that operates an international agency, as well as an agency.
Article 9
SUPPORTED CONTACT
1. a) The management, control or capital of the Minister of State, or indirectly, in the management, control or capital of the Government of Azite, or
b) An Akit State and other form of government, or indirectly. In the management, control or capital of the Akit State community,
and both, both commercial or financial services between the two teas Or, because of those conditions that must be caused by people who need to be among the people who need to be, but because of those conditions that are happening or because of those conditions that are being created, the benefit of that person is the benefit of that life. can be added and taxed accordingly.
2. The fact that a State of the State should include in the earnings of its own private property and tax the taxation of the country, which is taxed in the other State of the World, includes the earnings of the state of the state, and the first mentioned state, the profit of the state, was a two-step drive. If there were no gains as a result of the computations that were later discussed in the case of the first mentioned State, the state of which was first mentioned in the case of the first mentioned state. If the decision was in place of this specification, it was received over that profit. will make the necessary corrections in the amount of the tax. When making this correction, the other provisions of this statement will be taken into consideration, and the competent authorities of the United States will be consulted on the need.
Clause 10
THEMES
1. They were paid to a member of the State in a State of Love, a member of the State of the State, which may be taxed in this other State.
2. However, they may be taxed at the same time that the company made the payment of the dividend, in the case of the Devlet and the State of the State, but the true beneficiary of the dividend is the State of the World, in the way it is. The lower tax rates will not take place:
a) The actual beneficiary is the capital of the dividend payee (capital social) In a period of two years before the dividend payment, at least 25% of the dollar, the company has been paying for less than two years, while the company is holding a company that holds it during the period of time (except for the partnership). the "5%%" of the dividend amount; or
b) 15% of the amount of the gross dividend in all other cases.
Authorities of the United States are involved in the implementation method of these repositions They're going to determine their way through. This fikra will not affect the taxation of the company in the earnings direction, which has paid dividend payment.
3. The term "dividend", used in this material, is based on revenues from stocks, intifas, or indent rights, which are derived from the founding stocks or those of other rights, which may not be able to bear or contribute to the profits. Covers revenues from other company rights that receive the same treatment as income from taxation, according to the state of the state, which is the subject of the company's policy.
4. The winner of a commercial activity at the site of an office in the Diyker Devlette state, in which there is a commercial activity, after being taxed according to the 7th Amendment, is in the possession of the remaining part of the city in the company in which it is located in the State of Akit, in which the state is located in the state of the State of the Republic of Turkey. taxable according to their provisions, but the tax will not take 5% of the remaining tax on this way.
5. The true beneficiary of the dividend, which is a Combat State, is if commercial activity is found in the commercial activity of the company that pays the dividend, or it is a fixed place in the state of the state. 1 st and 2 ci fikra provisions shall not be applied if they are found in the activity and if there is an active view on this site or fixed site with the resulting contact. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.
6. In the event that the 4th fikra provisions of this Article are to be withheld, a Company with a State of the Union, a profit in the Union of Turkey in profit or income, that the State cannot receive any tax on the dividend paid by this company. The exception of this is that such items must be paid to one of the other members of this state, or if they have obtained the dividend and have an active place between a site or a fixed site in this state. In the same way, this state cannot receive a no-profit tax due to the unimposed earnings of this company. Whether or not the resulting dividend or revenue gain is entirely or revenue is not the result of any gain or revenue from this state.
Article 11
FAIZ
1. The interest paid to a member of the Akite State and the other in the State of the World may be taxed on this other Devlet.
2. However, this interest may also be taxed according to the Minister of Atkit and the State of the State, but the true beneficiary of the interest will not address the tax rate in which the State of the United States is a member of the State of the World:
(a) is a two-year period of debunks paid by the interest of the interest the amount of 10 'u;
(b) 15 per cent of the gross amount of interest in all cases.
3. 2 see the ncr provisions:
(a) The Turkish Central Bank, in Portugal, from the interest of the interest, Portugal to be exempted;
(b) The Central Bank of Portugal is exempt from the Turkish tax due to the interest in Turkey will be held;
(c) Government of one of the States, political or administrative subdivisions, or The local authorities will be exempted from the interest rate at the other Devlette State, which will be exempted from the tax.
4. The term "interest" used in this material is derived from all types of creditless revenue and, in particular, bonds or debt bonds, regardless of whether or not to guarantee the mortgage guarantee or to contribute to the debtor. refers to premium bonuses and bonuses to such securities, bonds or debt as they come from.
5. The true beneficiary of the interest in a Kite State team is found in commercial activity there, with a stable site in the country where the interest is obtained, or a fixed place in the state of the other, in a free business. If it is found and there is an active view of this office or fixed site with the payment of that interest, the provisions of the 1st and 2nd fikra shall not apply. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.
6. The interest paid by the perpetrator of a State of the State will be accepted in that State. However, the interest-paying person, whether it is a member of a Kite State or not, has a fixed place or fixed place with a debt-to-credit relationship, which is causing interest to pay off interest in a Âkit Devlette, and interest is in place of this place or place. This product will be considered to be obtained in the state where the site or the location of the site is located.
7. The amount of interest paid in the credit is due to the fact that there is no such relationship, due to the fact that there is no such relationship, because of the actual beneficiary between the payable or both, or both, and the amount of money that is not. On the other hand, these provisions will only apply to the most recent amount of the mentioned quantity. In this case, the additional payment will be taxed according to the legislation of each of the Azoys, under consideration of the other provisions of this statement.
Article 12
COST-OUT-OF-RIGHTS
1. The cost of an invigorate value, which is paid to a member of the Aper State and in the other, is taxed on this other Devlet.
2. However, the actual costs of money, in which they are obtained, are taxable according to the legislation of the Government and the State of the State, however, the true beneficiary of the cost of the purpose of the real beneficiary is the tax which will be taken in this way. It will not waste 10 per cent of the gross amount of the cost of the cost.
3. The term "Gayrimaterial rights" used in this material, including films and bands used in radio and television broadcasts with cinema films, is a form of literary, artistic or scientific copyright of any kind, of any kind, of patent, of any kind. the use or use of the model, plan, secret formula or production method, or use of the right, commercial or scientific experience, or use of commercial or scientific equipment, or use of the product or use of the production method or use of the production method refers to any payment that is made of the use of the right to use.
4. The true beneficiary of the cost of an Akit State is a real beneficiary, if it is found in commercial activity there, or a fixed place in the other state, in the same company that is located in the other, in which there is a land in the country. if free professional activity is found and there is an active line between the right or the default and the fixed site, the 1st and 2nd fikra provisions shall not be applied. In this case, the provisions of article 7 or 14th will be applied.
5. The value of the amount of money that is paid for by the Government of a Profit Government will be accepted in that State. However, the person who pays the price for diligent is either a member of the State or not, or has a fixed place, or a fixed place, with the right or the heir to pay the price of an artifical rights in the State of the Endeavor. If the claim is due to this place or fixed place, the property or fixed location of the property or fixed site will be considered to be obtained.
6. The amount of the amount of money that is paid in terms of use, right or information is real, because of the fact that there is no such relationship between the other and the actual beneficiary between the other or both, because of the special relationship that exists between both and one person. The provisions of this clause will only be applied to the most recently mentioned quantity, in the amount that will be determined in the dialeddar. In this case, the additional payment will be taxed according to the legislation of each of the Azoys, under consideration of the other provisions of this statement.
Article 13
CAPITAL DEARABLE EARNINGS
1. Earnings per share of the real estate entities, which are included in the 6 ncu clause, are taxable in this State of the Republic of Turkey.
2. Securities that are owned by the commercial entity, including the commercial entity of a Kite State team, including the commercial entity, or in the case of a Âkit State party to perform free business in the Aper Transfer State. Proceeds from the disposal of the assets may be taxed in this other State, including the benefit of this location (either with or with all contact), or from the disposal of the fixed site.
3. In the event of a State Secretary of State, an international traffic-led ship, aircraft or land transmission, or proceeds from the disposal of securities related to the transport of the ship, aircraft or land transmission, are only in the process of being sold. will be taxed in this Devlette.
4. Earnings of 1, 2, and 3. In the event of an overhaul of the remaining assets, will be taxed only in the Fuel State, which is the only person who has been left out of the world.
5. The 4th fikra provisions were made by a Turkish government, in which a member of the other Kite State sold their shares, representing the state's first mentioned state, which represents more than 25 per cent of the main capital of a company. will not affect the right to taxation, but the initial mention of the trade in question must be made to a member of the State and the time period between power and disposal must not take a year.
Article 14
FREE TRADE INTEREST
1. In the event that a State team has obtained free vocational services or other activities, it will be taxed only in this state. However, such services or activities are performed in this other State and will be eliminated by:
a) to perform such service or activities in this other state if it has a fixed location where it can be used continuously with the purpose; or
b) to perform such service or activities in this other state In any 12-month period, if a total of 183 days or more is left at one or several times, such revenue may also be taxed at the same time in the Aper Akte Devlette.
In such cases, the event will only be attributed to the fixed location in question, or income from the service or activities performed during the period of time, which is performed only during the current period of time, may be taxed in this Diyer State.
2. In the event that a Turkish State team has obtained free vocational services or similar activities, it will only be taxed on this State. However, such services or activities are performed in this other State and will be eliminated by:
ettiðia) this is the service or its activities in such a state. if it has a location; orb) period or periods when services are performed, without interruption of any 12 months If a total of 183 days in the period,
revenue may also be taxed on this other in the ÂÂKit Devlette.
In such cases, the event says, only if it is not in question or in this language income that can be attributed to the service or activities performed, it can be taxed on this other Devlette. In both cases, such as an income that can be attributed to the business of a private state in the other state, this country may choose to be taxed according to the provisions of Article 7 of the State. This election will not affect the right of the other State to tax the tax on such revenue.
3. The term "free trade activities" is a scientific, literary, artistic, educational and educational activities carried out in particular as a result of the work of doctors, lawyers, engineers, architects, workers and accountants. It covers other activities that require special professional skills through its activities.
Article 15
FAMILY-BASED FAALAS
1. The provisions of the Articles 16, 18, 19, 20 and 21 are to be saved, and the fee, salary, and other such revenues obtained by a Turkish State team, in a service indirect, are not intended to be performed in this state, unless this service is performed in the other Profit State. will be taxed. If the service is performed on the other Devlette, the proceeds from here will be taxed on this other Devlette.
2. Looking at the 1-pearl provisions, a Profit Government team has achieved the right to a service in the State of the Republic, eyer:
a) Revenue resulting in any twelve month period starting or ending in the related calendar year in the if a total of 183 days is left to not be started in one or several times, and
b) Payment is made by an administrator who is not the member of the other State, or if it is issued to such an entity, and
c) Payment is only first mentioned if it does not make it from a place or fixed place that the company has in the other state It will be taxed in the state.
3. The provisions of this article prior to this article were obtained by a Turkish government and a ship in international traffic, a service that was executed in the plane or land transmission. taxable.
Article 16
PAYMENTS MADE TOMANAGERS
is a member of the Board of Directors or supervisory board of the company, or a member of the Supervisory Board, which is the member of the Aper Industry Charges and other such payments, which may result in the fact that they are members of any other body-like activities, may be taxed at this other State.
Article 17
ARTIST AND ATHLETES
1. In the case of 14 and 15 articles of article, an artist of the State, a theatre, cinema, radio or television artist, has achieved the activities of a musician or a sportsman in the activities of the other Akit Devlette in the event of the activities. They would come, they would be taxed on this other State.
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. the Akit Devlette, which is performed by its activities, is taxable.
3. An artist or athlete's income from activities performed in a Kite State, the state of which the state of the state or the administrative sub-department or the neighbourhood administration of the state, in which such a visit was made, was made entirely or substantially. If it is to be used, this will be the exception of the data.
Article 18
RETIREMENT MAAZS
The provisions of the 2nd section of the1919th clause are intended to remain in place of a Sakite State team for the remaining part. Pensions and other such payments, paid in this state, will only be taxed in this state. This provision will also apply to regular payments, which are being sold to a Akkit State team.Article 19
PUBLIC TASKS
1. a) The fee, salary and other of the pension, sold by the State, sub-division or administration by the State, subdivision or administration of services given to him, the political or administrative sub-section, or the district administration. such payments may be taxed only in this State.
b) However, when the service is performed in the Devlet Devlette, and the real person is a mutant of that state, I promise. the fee, the salary, and the other such payments will only be taxed on this other State. However, this is:
i) to be a citizen of that State; or
ii) not only to this state in order to execute this service only
is required.
2. a) Once the State Department, the political or administrative subsection, or the district administration or the funds that have been created, these are the pensions paid for by a real person in the service of this State, subsection, or administration. It will be taxed in the state;
b), however, is a member of the real world, in the event that the State is a member of the state and its citizens. will only be taxed in this other Âkit Devlette.
3. A State of the State itself, the political or administrative subdivision, or the administrative services run by the services of the neighborhood, paid for the salaries of 15, 16, 17 and 18 of the pensions, including salary, salary and other similar payments. the provisions of the substances shall be applied.
Article 20
PROFESSORS AND RESEARCHERS
A State of the Union, a university, high school, school, or the government of this State that has not been able to profit from the government Whether it is intended to do scientific research or to perform scientific research, or an official cultural program, visit and take this visit immediately before or immediately preceding the visit of the Aper Circuit. from the date of the first visit to this Devlet For a period that does not work, they will be given an exception to this State of the State or future.
Article 21
OTHER RETRADEMARKS
1. For the cost of livelihood, livelihood or professional education, a student or intern with the purpose of a visit to the State of Akili or immediately preceding the State of Love, the State of which is the first to be mentioned, or in the State of the Republic alone, is to pay for my livelihood, livelihood, or professional education. Payments made from government sources will not be taxed in this State.
2. Time or durations of 183 days in a calendar year to win applications for the first ever mentioned Devlette person, or the first mentioned State of the Devlet State visit, or immediately prior to a visit to the State of the Republic visit. Any fees obtained by an intern or an intern who are in service will not be taxed in this other State.
Article 22
BUTTON-ON-OPTIONS
1. Some of the revenue elements that are not mentioned in the earlier articles of the State of a Akkit Government will be taxed only in this State.
2. Except for the revenue from real estate assets described in the 2 ncis of the six-ncis of matter, a member of the company in the State of Akit in commercial activity, in which the company obtained the proceeds, in commercial activity or in this other If a fixed place in the state is found in free professional activity and the income is paid for or there is an active view of this place or fixed site, the 1st frisk provisions will not be applied to this income. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.
FOURTH PART
RESOLVE DATA IN THE TEXT
Article 23
RESOLVE DATA IN THE TEXT
1. Portugal to double taxation will be avoided in the following:
a) When a Portuguese team makes a taxable income available in Turkey in accordance with the provisions of this Statement, Portugal will allow for a valid amount of tax paid in Turkey, which will pay off the revenue of this candle.
The revenue that is subject to taxable income in Portugal is calculated before the mapherage. The amount of tax will not be expected.
b) In accordance with any provision of the Meaning of a Portuguese, an exception is the exception of this State in this State in the case of the Portugal may also consider the exception of its revenue when calculating the tax on the remaining income of this candle.
c) (a) a company with a Portuguese team (except common), which is a member of the Portuguese, is a member of the United Kingdom. In a period of two years before the Portuguese team's dividend payment, Portugal, the Portuguese team, has been on a period of less than two years in a continuous two-year period prior to the payment of the company's dividend, which has been exempted from institutions in Turkey. The company has been charged with the development of the company. It will allow 95 per cent of these dividend items to be reduced, including the tax on the tax, with the fact that it has kept at least 25 percent of its capital from the dollar.
2. Double taxation in the direction of Turkey will be avoided:
a) The provisions of Turkish legislation that allow the Turkish tax to be withheld from the Turkish tax are to be saved. the Portuguese tax revenue (including profit and tax revenue) of a Turkish candle, and the Portuguese tax payable upon which the Portuguese legislation is required shall allow the Turkish tax to be paid through this income. in the future However, it will not increase the amount of Turkish tax calculated prior to the crop, which can be attributed to this revenue.
b) In accordance with any provision of a Turkey, an exception is the one that is given in Turkey in accordance with any provision of the In the event that it is obtained, Turkey may also consider the exception of its remaining income while calculating the tax on the remaining income of this candle.
PART OF ACHAPTER
SPECIAL PROVISIONS
Article 24
SEPARATION NOT MADE
1. The citizens of a State Government, in the same way, are not able to tax or pay for taxes, especially from mutitions, especially from mutias, the citizens of the state in the country, in the other hand, are responsible for the state's government. They will not be subject to a taxation or a liability to the public. This provision will be applied to the non-conunuate of one or both of the States, regardless of the 1 th provisions.
2. In order to hide the provisions of the 4th section of the 10th Amendment, a State of the State's foreign policy, in the other State of the Republic of Turkey, has less lehe than those who have carried out the same activities in the other state, in the other state. It won't be up to you.
2. The interest of a State of the Republic of Turkey, excluding the provisions of the provisions of the 7th section of Article 11, of the 7th of the 11th Article, or 6 of the 12 articles of Article 9, is the interest paid to a member of the State of the Republic of Turkey, the interest of the purpose of the purpose of the purpose of the purpose of the purpose of the State of the Republic. In the determination of the taxable earnings of this country, such payments will be able to be downloaded as a result of the first mentioned state in such a case.
4. The first mentioned State of the State, the state of which the State, the government, is the first to be mentioned by one or several of the parties of the State, the government, or its fully capitalising, or whose capital is controlled by the government. They will not be subject to the taxes or taxation of which they are subject or possible, or they will not be subject to taxes or other liability.
5. These provisions will not be understood as such that a Government has to apply discounts, taxes and matrah discounts to their own people, as well as in the case of the family of Azokit.
6. The provisions of this clause shall apply to the avranian taxes.
Article 25
BUSINESS UNDERSTANDING STYLE
1. One person, in the case of one or both of the countries in the World, created or created a tax on the provisions of this statement, in order to create or create a tax on the domestic legislation of the states. In accordance with the authority of the state's authority or the 1st of the 24th Article, the authority of the State Department may supply the authority of the authority to the authority of the State of the 24th, if the incident complies with the state's authority or the 1st of the 24th. The following will be done within three years of the initial declaration of an act that has resulted in a tax on the provisions of the Anthem.
2. It is committed to resolve the case through the means of meeting the competent authority of the country's government, in an effort to avoid a satisfactory resolution, unless the appeal is justified, but not the satisfactory solution, he said. He will. All the things that have come to understand, It will apply to the time changes in the domestic legislation of the Aşit States.
3. The competent authorities of the Aşit States will strive to resolve any strong or hesitation arising out of the interpretation or implementation of the State of the Union.
4. The competent authorities of the State States can communicate with each other or a joint commission of their own or their representatives in order to reach an understanding of the previous fissions.
Article 26
BALLGGUS DEEDECUS
1. As long as the competent authorities of the State States do not have the information or the information required for the execution of these provisions, the provisions of the legislation are required to execute the provisions of the internal legislation relating to the taxes under the scope of the They're going to put the information on my desk. Any information received by the State of the State shall be confidential, such as information obtained within the framework of that State's own internal legislation, and only with the tax or penalty enforcement or penalty of the taxes specified in this statement, or the law. will be given to the office or authorities (including criminal authorities and administrative installs), which are tasked with looking at the concerns and objections of the people. These people or authorities will only use the information in the form of these purposes. These people or authorities can open such information in court proceedings or when they are making judicial decisions.
2. The 1st fikra provisions, a State of the Azoth in no way:
a) Do not take administrative measures that do not comply with the legislation or administrative practices of the Keni or the other, the government;
b) information that cannot be obtained within the framework of the legislation or the normal administrative actions of the Keni or the other submit;
c) Any commercial, end, professional or commercial information that makes public information or public information public. Obligation to provide information about the same order as it is
Thecannot be interpreted to put it under the table.
Article 27
OFFICERS ON THEDROPOUT GOVERNMENTHÜVÝYETÝNDEKÝ
AND CONSULAR OFFICERS
The provisions of this statement are the general law of international law enforcement of officers or consular officers of the diplomat's government. The benefits of using the rules or the provisions of special understanding will not affect the financial details.
SIXTH SECTION
LATEST PROVISIONS
Article 28
CURRENT LEAVE
1. Each of the countries will report to the conclusion that the work envisioned in its domestic legislation has been completed in order for this to take effect. This statement will take effect on the date of the last of these notices.
2. The provisions of this statement:
a) in Portugal:
(i) In the direction of the taxes that are expressed in the source, the first of January following the current entry of this statement is the first for taxes that occur later or later;
(ii) The first day of January, or more, of the following year of taxes, followed by the effective taxes. For revenues that occur in any financial year that start
b) in Turkey:
The first day of January following the current date or later taxation period that follows for taxes related to the taxation periods that follow through the following:
will be applied.
Article 29
DON ' T REPEAL IT
1. This will remain in effect until a State of the Force is dissolved by the State. Each of the States does not understand it by issuing diplomatic means, at least six months before the end of any calendar year after the end of the term, from the end of a five-year period. It can be dissolved.
2. Do Not Understand:
a) in Portugal:
(i) In the direction of taxes expressed in the source, the following date has been followed by the date specified in the annulment of such annulment. the first day of the month or for taxes that occur later;
(ii) The first of January taxes is the first of the year following the date specified in the annulment of the annulment of the annulment of the annulment of the annulment of the annuies. for revenue that occurred in the financial year that started later or later
b) in Turkey:
The first day of January, or later, of the date that follows the date specified in the annulment of the annulment of the annuition of from the amount of taxes on each taxation period;
will not be convicted.
Full-authorized representatives who have signed these SERVICES FROM They signed the deal.
In theTürkTurkish, Portuguese, and English languages, all texts are equally valid, at 11 May 2005, It's arranged in Lisbon. English text will be in effect if there is no difference in the comment or application.REPUBLIC OF TURKEY IS PORTUGUESE REPUBLIC
ADINA
John [ Luis] Luis Campos e CUNHA
The Secretary of theDepartment of State and Finance Minister
PROTOCOL
Avoidance of Double Taxation in Altannin Taxes betweenRepublic of Turkey and the Republic of Portugal On the day of the signing of the agreement to block the Tax Evasion, the signing parties will have the right to understand that additional provisions are part of the process of understanding the additional provisions of the agreement.
6-ncu Attachment
As of article 6, the provisions of this item are obtained from the entities of the entity. It is also considered to be applied to revenues from operations for the maintenance or construction of real estate assets (property).
EkAttachment to the 8th Clause For the purposes of the 2nd section of the88th article, a company with a Sovereign State team, a Sovereign State, A consortium, or any similar consortium, is considered to be covered by gains in the consortium, or shares in the unit, in the United States.Attachment to the 10th Clause
as the third party of the 10th article, the term "dividend", The gains attributed to the performance of the Portuguese, in the direction of the wintry; It is considered to include revenues from the Turkish direction, the yacht fund, and the investment partner.
Attachment for 12 nciMaddeye
for the purposes of the 3rd part of the article, the term "gayrimaterial rights", or the term "gairimaterial rights", It is agreed to cover earnings from the use of the asset, whether the right or the efficiency of the asset, the right or the asset, or the savings it has received.
Attachment to the 14th Clause
As part of the 2nd article of the 14th Amendment, the 7th State of a Akitel Government, the 7th of which is a State of the Union, has been given a In the event that it chooses to be taxed according to the provisions of the clause, the tax received via the withholding of this language through such income may be reduced to the tax calculated on this income, under the provisions of Article 7 of this Article. EkAttachment to the 25th Amendment As the 2nd section of the2525th article, the taxpayer is responsible for the tax administration resulting from the decision. After being notified, it is understood that it has to request the return resulting from internal legislation within a period of time envisioned by the internal legislation.Full-authorized representatives who have signed these SERVICES FROM They signed the protocol.
In theTürkTurkish, Portuguese, and English languages, all texts are equally valid, at 11 May 2005, It's arranged in Lisbon. English text will be valid if there is no difference in the interpretation or application of this Protocol.
REPUBLIC OF TURKEY IS PORTUGUESE REPUBLIC
ADINA
John [ Luis] Luis Campos e CUNHA
The Secretary of State and Finance of theMinistry of
