Key Benefits:
IT IS APPROPRIATE FOR THE TURKISH REPUBLIC TO APPROVE THE DECISION TO PREVENT THE DECISION TO PREVENT WEALTH TAX ON TAXES, FROM THE REPUBLIC OF BOSNIA AND HERZEGOVINA.
DAIR LAW
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Kanun No. 5514 |
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Date of Admission: 1/6/2006 |
Article 1- signed in Sarajevo on 16 February 2005 "Turkey" It is appropriate to approve the Avoidance Of Double Taxation in Tax-based Received Taxes between the Republic and Bosnia and Herzegovina (BiH).
Article 2- This is effective on the release date of the Law.
Article 3- The Council of Ministers executes the provisions of this Law.
REPUBLIC OF TURKEY
ILE
BOSNIA AND HERZEGOVINA
ARRIVE BETWEENAND RECEIVE WEALTH ON VERGES
AVOIDING CONFLICT-OPERATION PREVENTION UNDERSTANDING
REPUBLIC OF TURKEY
ILE
BOSNIA AND HERZEGOVINA
Revenue and wealth With the desire to make a statement that prevents double taxation in taxes,
In the current state Understand:
Clause 1
CAPACITY COVERED
This means that one or both of the Skit States will be applied to the people.
Article 2
KAVRANAN VERGIFS
1. This means that no matter how much it is taken, it will come from a State or political subdivision or neighborhood administrations, and apply to taxes on wealth through wealth.
2. Taxes on the total amount paid or the total amount paid by the securities and taxes levied on earnings from the transfer of real estate or real estate assets, and taxes imposed on capital of this capital. All taxes, income and wealth, including total income, total wealth or income or items of wealth, will be considered as taxes, including the total income.
3. Specifically, taxes that apply to the deal are applicable:
a) in Turkey:
i) income tax;
ii) corporate tax;
(This will refer to as "Turkish tax");
b) in Bosnia and Herzegovina:
i) tax received through the Maasai;
ii) tax received over earnings of the telemarks;
iii) received over profit from economic and professional activities tax;
iv) tax on revenue generated from agricultural activities;
vergiv) tax on property;vi) received over revenue from property and property rights tax;
vii) revenue from copyrights, patents, and technical innovations tax;
viii) tax received over the gross revenues of real kibs;
(This will refer to as "Bosnia and Herzegovina 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.
Clause 3
GENERAL DEFINITIONS
1. From the purposes of this task, unless the text is predicted to the contrary:
a) The terms "State" and "State of the Digit" are required by the text. , refers to Turkey or Bosnia and Herzegovina;
b) The term "Turkey" is the sovereignty area of Turkey, its territorial waters, whether to search, operate, and protect the legal resources in accordance with international law, or the areas of sea used by the rights of sovereignty;
c) "Bosnia and Herzegovina", the sovereignty area of Bosnia and Herzegovina, its territorial waters, whether to search, operate, and protect the legal resources in accordance with international law, or the areas of sea used by the rights of sovereignty;
d) "Political subdivision" refers to Bosnia-Herzegovina, Bosnia and Herzegovina It refers to the Federation, Republika Srpska, and Brcko region;
e) The term "citizen" from a Akite State minister:
i) any other person with nationality or nationality of the Akit State real kishen;
ii) any status that is in effect with respect to the legislation that is in effect in the a legal entity, a partner, or association
refers to;
f) the term "Kishi" is a real person, a company, and other people who are doing it. includes any installation;
g) The term "February", as an institution, in terms of any institution or taxation to any installation that is being treated;
h) "The contact of the State of the Aper" and "the contact of the other Akitel 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;
i) The term "internationalistic traffic" is only known as the only of the Government of America. Any sign of any sign of ship, aircraft or land transmission is deployed by a tester with an active management center in a Fuel State, excluding the ship, aircraft or land transmission board, which is being actualized in the future. value;
j) "Authority for authority":
(i) in Turkey: the Ministry of Finance or its authorized representative;
(ii) in Bosnia and Herzegovina: Finance and Treasury Department or authorized
refers to.
2. Any term that is not defined in the expression, unless otherwise stipulate to the contrary, is used by the State of the State in the future, as a result of the implementation of the State of the Union in the case of the applicable taxes. The meaning of this term in the current tax legislation will be superior to the meaning given to this term in the other legislation of this State.
Clause 4
MUKOM
1. For the purposes of this statement, the term "A Instrument State" means that the State, including any political subdivision or neighborhood administration, has the state of residence, residence, legal center, place of administration or similar structure. it means the person who enters the payer due to any criteria. This term, however, does not include only the income from sources in that State or any other person who is subject to a tax due to the wealth in that state.
2. The state of the following will be determined in the case of a real person, with the provisions of the 1st fikra, as well as in the case of the United States.:
a) This is the state of the state where a home is only permanent. Will be accepted. If there is a permanent home in both Devlette, it will only be accepted by the state of the state, where their personal and economic relations are closer (the center 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, the machine will be accepted for the state of the state where the home is not the only one to remain;
c) If there is a home in which the Eyer is found to remain in both Develes, or if such a house is mentioned in both Devlette, it will only be accepted by the state of the state that it is a citizen of this country;
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 person who is in real part of the actual person will be accepted to the party of the Âkit State, where only the active management place is located, when both of these Azoys have been made of the first.
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;
f) Maden oasis, oil or natural gas well, hot water or natural gas Any location where resources are grapeed.
3. A 12-month period of continuing construction, construction, assembly or installation, or surveillance activities related to them, will be a place of office.
4. Any prior provisions of this clause will be considered to include the term "workplace":
a) Your facilities, contact property, or commercial property is only 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) only if a fixed location is a private property or business whether to receive a purchase or collection of 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) The only mention of a fixed location in the (a) to (e) to execute a few of the activities together; however, it is the preparation or performance of the activity that is the result of the execution of all of these activities in the fixed place.
5. One of the provisions of the 1st and 2nd feats of this Article, a part of which is likely to be applied to the 6-ncr of this Article-is a transfer to the name of a Velcro, moves to the name of a foreign bus, and to the name of this service. And if using this authority from the mutaden, the interest of this person shall not be made available in accordance with the provisions of this article in accordance with the provisions of this article, in the case of a fixed location. So, this is the government, this is the government, this is the government, this is the government. It will be accepted with any activity in which it has been actually;
6. A public bus, a Sitel Devlette, has a job in that state to carry out their work through an ongoing trader, general commission agency, or any agency that has status as a status quo in the status quo. 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.
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, real estate assets are used in agriculture (including balm production and its ability) and forestry. and its animals are fixed or otherwise known for the right to real estate ownership, real estate inaction rights and mining, resources, and other real estate, sources and other sources of legal property. It will cover the rights on the payments when it is already in place. Ships, planes and land transport will not be considered as real estate assets.
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 Fıkra provisions of this Article will also be applied to the proceeds from real estate assets used in real estate assets and income from real estate assets in a foreign property.
Clause 7
FINANCIAL GAINS
1. The acquisition of a Profitable State for State community 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, it may be taxed in this other State, with the amount of earnings that can be attributed only to the amount of money that can be attributed to the business.
2. In the event of commercial activity there, both in the Azoit Devlette, the same as it was in commercial activity to ensure that the provisions of the 3rd fikra of this Article are in commercial activity there, in the case of a State of the Republic of America, in the case of a State of the Republic of Azite. as a result of a number of similar conditions, such as the same or similar activities, and a full profit from the person who had been involved in the event, it would be a total gain, regardless of the number of people who were completely involved in the development of a place.
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. In the event that an ad-free winner is likely to be determined by the fact that the company's total earnings per unit is mutable, there is no provision envisioned in the 2nd of this Article, this is the case of the State of the Money, will not prevent the taxable gain from setting it with such a payout method. However, the method of sharing will be so that the result will be in accordance with the principles set out in this matter.
5. No gain will be attributed to the office of this location only if it has been purchased for goods or trading on behalf of the United States.
6. For the purposes of this material, it will be determined in the same way every year, as a result of a gain, rather than a reasonable and current reason, is not a result of the purpose of this material.
7. 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
DENY, AIR, AND LAND VACATION
1. In international traffic, the proceeds from the ship, aircraft or land transport transport will be taxed in the Akikit Devlette, where only the effective management center of the company is found.
2. For the purposes of this matter, an earnings call for the State's government to produce ships, aircraft or land transport in international traffic has been achieved as a result of the gains imposed by the 1st fikra provisions. It will also cover the gains from use or leasing of containers with the code.
3. In the event that the ship was registered, there was no port where the ship was registered, if there was no port on which the ship was registered, the ship was the man who was the site of the ship's ship, said in the ship's boat, in which the ship was registered. will be accepted.
4. The 1st fikra provisions will also be applied to a partner, a partner, a partner or an international agency, as well as the proceeds from the transaction.
Article 9
SUPPORTED CONTACT
1. a) The management, control or capital of the Minister of Government, or indirectly, in the form of a Monopoly State, or indirectly, or
b) The same as the same, or indirectly, the state of the State's contact and the management, control, or capital of the Union of Turkey's government,Âkit
and both, both commercial or financial services between the two teas Due to the conditions in which the people of the people who are going to be looking for, or being created, they do not show themselves in one of the people due to the conditions that are happening, but due to the conditions that have been caused by the people who are going to be able to win that life. is added and can be taxed accordingly.
2. The fact that a State of the State should include in the earnings of its own private property and tax taxation include earnings from the country of the other State, which is taxed in the other, and the first mentioned state has no profit, two telebuses. in the event that the required conditions are not the result of the results of the first mentioned State of the United States. If the State determines that it is in place of this specification, then it will not be the result of any such benefit. will make the necessary corrections to the quantity. 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 government and the state of this state, but the true beneficiary of the dividend is the case of the State of the World, which will be taken in this way. tax-on-tax rates will not be repaid:
a) The real beneficiary is the capital of the capital of the dividend payout if a company that holds a minimum 25 percent (except for the partner), is 5 percent of the amount of the gross dividend;
b) 15 per cent of the amount of the gross dividend in all other cases.
Authorities of the States are authorized to apply these methods to They will be able to identify them through the way they are understood.
This fikra is a dividend payment of dividend payout will not affect taxation.
3. The term "dividend", used in this material, is derived from stocks, intifas, or intifa rights, mining shares, constituent stocks, or other than the other rights that bear the gain. According to the state of the state, the company that conducts the company with revenues, the revenues from other companies that have received the same treatment as income from taxation, and the direction of Turkey, at the same time, the fund and the also refers to the revenue generated from the partnership.
4. The winner of a commercial activity in commercial activity with an office in the Diyker Devlette state, after being taxed according to the 7th Amendment, found the remaining part of the article in the company in which it was found to be in accordance with the 2-ci fund of the article. to be taxed.
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. If it is found in its activity and there is a significant view of this business or fixed place, the 1st and 2nd fikra provisions will not be applied. In this case, the provisions of this Section 7 or 14th clause will apply according to the event.
6. The provisions of the 4th issue of this Article are intended to remain withheld by a company with a State of the Republic, in which the Minister of State has gained profit or income from the Minister of State, to be paid for or obtained by a member of the State's Association. It cannot receive any tax on the dividend paid by this company, except with the status of an office located in the other State or a fixed site, except that they have an active experience. In the same way, this state cannot receive a no-profit tax due to the unimposed earnings of this company. Whether or not the selected dividend or revenue gain is entirely or revenue does not result in a profit or revenue earned in this Devlette 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 be taxed according to the Minister of Atkit and the State of the State; however, the real beneficiary of the interest is the 10% of the gross amount of your tax interest in this country. It will not.
Authorities of the States are authorized to enforce this method of They will be able to identify them through the way they are understood.
3. 2 interest arising from government loans, regardless of the provisions of the 2nd fikra;
a) in Turkey and Bosnia and Herzegovina (BiH) or Bosnia and Herzegovina If it is paid to the Bank, it will be exempted from tax in Turkey;
b) to the government of the Republic of Turkey and the Republic of Turkey in the Republic of Turkey If it is paid to the bank or the Turkish Eximbank, it will be exempted from the tax in Bosnia and Herzegovina.
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 Âkit Government team is found in commercial activity by the entity in which interest is obtained, or if it is found in free professional activity with a fixed location in this other Devlette. if there is an active interest in this office or fixed site, the 1st and 2nd fikra provisions of this item will not be applied if there is an active interest in this office or fixed site. In this case, the provisions of this Section 7 or 14th clause will apply according to the event.
6. A State of the State itself, a political subdivision, its neighborhood administration, or the interest paid by a member of this State, will be accepted in that state. However, the interest-paying person is either a member of a Kite State or has a fixed place, where the debt-to-credit relationship is causing the interest to pay off an interest in a Âkit Devlette, and interest is in place of this office or fixed place. It is assumed that the interest, location, or fixed location will be obtained in the Akit Devlette.
7. The amount of interest paid in the credit is due to the actual beneficiary of the payable, or the actual beneficiary of the interest, or both due to the fact that there is no such relationship between the other and the actual beneficiary of the interest between the two and the other. The provisions of this matter will only apply to the most recent amount of the most recently 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 may be taxed according to the State and the State of the State, but the real beneficiary of the cost of the money is the tax, if the State is a member of the State of the Real. It will not charge 10 per cent of the gross amount of the cost of the gaysum.
Authorities of the States are authorized to enforce this method of They will be able to identify them through the way they are understood.
3. The term "Gayrimaterial rights," which is used in this material, is a form of literary, artistic or scientific copyright, including films and bands used in radio or television broadcasts with cinema films, and all kinds of patents, credits, and credits. The use of the mouse, pattern, or model, plan, secret formula, or production method, or the use of the production method, or the term, commercial or scientific experience, refers to any payment made at the time of the accumulation of information.
4. The real beneficiary of the cost of an Akit State is the real beneficiary, if it is found in commercial activity with the entity in which the price was obtained, or a fixed location in this other Devlette. if it is found in professional activity and there is an active view of the right or the right to be paid, the provisions of the 1st and 2nd terms of this item will not be applied. In this case, the provisions of this statement will apply the provisions of 7th or 14th Amendment.
5. The State itself, a political subdivision, its neighborhood administration, or the cost of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of the purpose of this State to be paid by a member of the State shall be accepted in that state. However, a person who pays the price for diligent eligibility, whether or not, has an obligation to pay the right to an illegitimate claim in a Kite State, has a fixed place or a fixed place and is entitled to an invigorate claim. The price will be obtained from this site or from the fixed site and will be accepted in the State of the State where the cost of the property or fixed place is located.
6. The use of the amount of diligent rights paid for use, right or information, is no such relationship, because of the actual beneficiary of the property and the actual beneficiary of the non-real estate fee, or both, and the private relationship between both. If the actual beneficiary is to be determined between the borer and the actual beneficiary, the provisions of this clause will only be applied to the most recently 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 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 (either alone or with all contact), or from the disposal of the fixed site.
3. The proceeds from disposal of securities related to international traffic, aircraft or land transmission vasses, or ship, aircraft or land transmission vasses were sold, but only the effective management of the company. It will be taxed in the Akit Devlette.
4. Profit from disposal of the remaining assets of this Article 1, 2, and 3 will be taxed only in the area where the muchas of the muchas are the muchas.
Article 14
FREE TRADE INTEREST
1. The revenue of a Aper Government team in the event of free vocational services, or other activities, will be taxed only in this State, but;
a }, continually performing activities in the other in the Aper Industry State If it has a fixed location, then only the revenue that can be attributed to that fixed site can be taxed in this other, in the Azit Akut Devlette; or
b) One or more of the related financial years in the other Aper Transfer State If a total of 183 days or more were left in the period, then the income from the activities performed in the diker in the Turkish Akut Devlette may be taxed in this other State.
2. The term "free vocational services" is a scientific, literary, artistic, educational, educational, educational, professional, lawyers, lawyers, engineers, architects, workers, accountants. activities.
Article 15
PRINTED INTEREST
1. In order to retain the provisions of Article 16, 18, 19, 20 and 21 to retain the provisions of a Profit State for a service, the salary, salary, and other such revenues are not only in this State of the State unless this service is performed in the Devlette 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 1st of the 1st frigid provisions of this Article, a PROFIT STATE has achieved the right of a service in the State of the Republic, eyer:
a) Revenue resulting in the fiscal year related to the other state Or, if a total of 183 days at a time, for a period of twelve months ending or ending, and
b) Payment by an informal or non-conserved state of the other State. if an issuing name is called, and
c) Payment is either from an owner or fixed term that the owner has in the other state. from the location, if notkaynaklanmazsa
will be taxed only on the first mentioned Devlette.
3. The revenue of this Article, which is obtained by a Profit Government, is the revenue of this item;
a) An execution in a 12-month period that does not become a place in the Dianer State services, such as the construction, assembly or installation project, or control activities related to them,
b) A ship, aircraft or land transmission that is being pushed into international traffic Services that are performed in the process
halindewill be taxed at this time if paid for by.Clause 16
PAYMENTS TO MANAGERS
A policy of the State team, which is a member of the State's State of America. as a member of the board of directors, fees and other such payments may be taxed on this other Devlette.
Article 17
ARTIST AND ATHLETES
1. In order to look at the provisions of 14-and 15-pearl items, an artist of the State or an artist, such as theatre, cinema, radio or television artist, or a musician, or an athlete, has performed in the activities of Akit Devlette in the event of the activities of the other. They get it, it's taxed on this other, in the Devlet.
2. If an artist or athlete's performing business comes from activities, whether the artist or the athlete himself is directed to a woman, the income is a part of the State of the Azores, or seven, 14, and 15, of which the government is. It is taxed in the Akit Devlette, which is the executive of the artist or the athlete's activities, to be used.
3. It comes from the provisions of the receipts in this Article, an artist or athlete who has a State of the Union, or the sport in which the sport is performing in the other in the Turkish State of America, both in the State of the Republic of Turkey. If performed within the framework of the sport ' s education program, only this state will be taxed.
Article 18
RETIREES
To hide the provisions of this section of the 19th section of section 2. They will be taxed in this state only if they are paid retired people and other similar incomes paid for by the passage of a Proceeds to the State of the Union.
Article 19
PUBLIC TASK
1. a) A charge of the State, subdivision or administration of the government, which is provided by the State, subsection or administration for the services granted by a real person to himself, a political sub-section or a neighborhood administration, is the remaining wage, salary, and so on. payments will be taxed only in this Devlette.
b), however, when the service is performed in the Devlet Devlette, and is real When the government is a member of that state, the fee, the salary, and other similar payments will only be taxed in this other State. However, this is:
i) being a citizen of this State; or
ii) not only did this state transition to its status to perform this service.
is required.
2. a) A State of America itself, a political subsection or a neighborhood administration or funds that have been created by the services of this state, the subdivision or the neighborhood administration paid retired people who are paid for a real time. will be taxed in this Devlette.
b) However, the real world is a member of the State of the World, and the If it is not a citizen, the pension will only be taxed in this other-in-the-place, Azit Devlette.
3. A Department of State itself, political subdivision, or other business-related commercial activities, including fees, salary and other similar payments, and pensions of 15, 16, 17 and 18 percent of the pension The provisions of this document are applied.
Article 20
OTHER REPOSTED
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. In the event of payments made from non-covered by scholarships, scholarships and non-contained in the 1st frigate of this Article, a student or an intern mentioned in the 1st storm, during the course of his or her professional skills, visited the State of the World in which they visited. The same exemption, exception, or discounts applicable to the taxes that apply to their contact will be eligible.
Article 21
PROFESSORS AND OTHER PROFESSORS
1. A State of Love, a university in this State, a school, school, or other general admission to the public institutions to pay or scientific research to visit and to make this visit immediately before or immediately preceding the visit of the Republic of Turkey. This is the first time the State has obtained any of the resources from this State in a period of not two years from the date of the first visit to this State for the purpose of this state, the State of the State said. The tax will be the exception.
2. For the sake of public interest, the 1st frictions provisions of this Article shall not be applied to the revenues obtained, especially in the interest of the specific individual or the interests of the people.
Article 22
LANGUAGE GELS
1. Some of the revenue elements that are not stated in the earlier articles of the State of a Akkit Government will be taxed only in this Devlet.
2. Excluding the income from real estate assets described in the 2-nci fund of the 6-cent clause, a beneficiary of the income is a beneficiary of the income in question, in commercial activity, with an office located in the other Akitel State, or 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 this Section 7 or 14th clause will apply according to the event.
Article 23
FORTUNE
1. The wealth of real estate assets, which is mentioned in the 6 ncu clause of the State of a Kite State, may be taxed in this other Devlette.
2. A securities of the Securities of a State property, including the active part of a State-owned business, or a fixed place in which a State team can use it to conduct free business in the Akkit Devlet. A wealth of assets can be taxed on this other State.
3. The ship, aircraft or land transmission vassing in international traffic, and a wealth of securities relating to the operation of aircraft or land transmission, only to find the effective management center of the company. It will be taxed in the state
4. All the wealth elements of a Âkit Government team will be taxed in this state alone.
Article 24
PREVENT TAX VERITABLE
1. In accordance with the provisions of this Ruling State, the first mentioned State, or in possession of a wealth of income or wealth of wealth, is the State of the Union;
(i) revenue in the revenue state that hits the revenue of this candle the amount of tax that is paid through it,
(ii) paid by tax, which hit the fortune of this candle, Amount to a wealth tax
will allow the mashup.
However, in both cases, the other Devallette It will not increase the amount calculated before the crop, which can be taxable or attributed to the service.
In accordance with the provisions of this Anit, a Profit is obtained by the State team If the income or the wealth of ownership is exempted from this State, this State may also consider exempted income or fortune when calculating the tax of the remaining income or fortune of this population.
2. The purpose of the case in the State of the Republic is that the tax paid in the other State of the Republic will be paid for in the other state, but the tax matters that are regulated by the country's economic interest in this State are intended to be regulated. are considered to include taxes that are either downloaded or not received. These fikra provisions will be applied for a period of 6 years after the current date of entry. This period can be extended by understanding the authorities among the authorized authorities.
Article 25
SEPARATION OF SEPARATION
1. A State of the State's citizens, in the other part of the State of the World, say that their citizens, especially in the direction of the government, are less likely to tax or leave taxes, or more, whether or not they are involved in the future. They will not be subjected to taxation or to those who are subject to it.
2. In a state of the Republic of Turkey's business, the country has less lehe taxation than the other State's activities, including the 4th Fıkra provisions of the 10th Amendment, a company in which a State's foreign policy has been held in Devlette, and other countries have been working on the same activities. It won't be up to you. This provision will not be understood as if a Âkit state has to apply discounts, taxes, and matrah discounts to their own party or familial states, and to implement the fuel-tax product.
3. The last of this is the interest paid to a member of the State of the Republic of Turkey for an interest in the State of the Union, excluding the provisions of the 7th of Article 11, or the provisions of the article 12, of the article. And other payments will be made in determining the taxable income, as such payments are made to a member of the state, which is the first to be mentioned in the same conditions. In the same way, in the determination of the taxable wealth of a State government, the debt of the country's taxable wealth, in the determination of the taxable wealth of this foreign policy, was the first to be done by the state of the state. will be downloaded.
4. The first mentioned State of the State of a State of the World, in which one or several parties of the State of the World, in the State of the Azite, or its fully capitalising, or whose capital is controlled, is the State of the State of the State. 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. The provisions of this clause shall be applied to the taxes mentioned in the 2 clause of this Article.
Article 26
BUSINESS MANAGEMENT PROCEDURE
1. One person, in the case of one or both of the countries in the World, created or created a taxation that is not in accordance with the provisions of the State of the Union, is the result of the state's civil regulations envisioned in the domestic legislation. the competent authority of the government in which it is a member of the incident, or if it complies with the 1st of the 24th Article, to the competent authority of the State of the Jurisdiction. 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. If the authority finds the right to appeal, and cannot be resolved, he will make an effort to deal with the competent authority of the country, in an attempt to avoid a further taxation of the State. Any considerations will be applied to the time left in the domestic legislation of the states in the United 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. At the same time, the authorities can also dance to avoid double taxation resulting from situations that are not addressed in the situation.
4. The competent authorities of the Atakit States can communicate with each other in order to reach an understanding of the issues outlined in the previous series of frisks. If verbal information is required to reach the point of understanding, it can be conducted through a Commission channel that is one of the representatives of the authorized authorities of the Âkit States.
Article 27
EASY TO DEAL WITH THE BUSINESS
1. The competent authorities of the State States are required for the execution of the provisions of the internal legislation relating to the duties of the Union, unless they have the information or the compliance with the information required for the execution of the provisions of this Statement. They're going to put the information on my desk. Information source is not associated with items 1 and 2 of this section. 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) to the legislation or administrative applications of the Keni or the other the administrative precautions that will not fit;
b) legislation or normal administrative actions of the Keni or other submission of information that cannot be obtained within the frame;
c) Become any commercial, sannin, professional or commercial item. giving information that brings information or ownership to the public order;
cannot be interpreted to put it under the obligation.
Article 28
CLERMAT GOVERNMENT OFFICERS AND OFFICERS CONSULAR OFFICERS
The provisions of this statement are either civil servants or consulates on a diplomat's government. It will not affect the financial details of the civil servants ' general rules of law or the provisions of special understanding.
Article 29
CURRENT LEAVE
Each of the States has its own internal state to take effect. will inform the diplomatic means of the completion of the regulations stipulate in the legislation. This statement will be effective at the time of the last of these notices, and provisions for taxes on the first day of January or every taxation period in January following the current effective entry of the State.
Article 30
CURRENT WITHDRAWAL
This information is in effect until it is dissolved by a Âkit State. It will stay. Each of the States can annully by issuing diplomatic means at least six months prior to the end of any calendar year after the current date of entry, which is under way to the conclusion of the current date. In this case, the State shall not be sentenced for taxes on the first day of January or any later taxation period that follows the year of the annulment of the annulment of the annulment.
This is the fully authorized representative of the United States, who has signed such signatures, and They signed the deal.
in the English language, 16 February 2005, It is organized in Sarajevo.
REPUBLIC OF TURKEY BOSNIA AND HERZEGOVINA
ADINA
(Israel)
