PREVENTING OUTPUT FROM THE TURKISH-REPUBLIC GOVERNMENT BETWEEN THE GOVERNMENT OF QATAR AND THE GOVERNMENT OF THE GOVERNMENT OF QATAR UNDERSTANDING
ELIGIBLE FOR APPROVAL
Kanun No. 5513
Date of Admission: 1/6/2006
ARTICLE 1- The Republic of Turkey, signed on 25 December 2001 in Ankara, Turkey The Government and the Government of the State of the State of the State of the State of the State of the State of the State of the State of the State of the State of the State of the State of the State of the Government of the Government of the Government of the Government of the State of Qatar agreed
ARTICLE 2- This is the date on the release date of the Law.
TICAD 3- The Council of Ministers executes the provisions of this Law.
REPUBLIC OF TURKEY GOVERNMENT
CALLING THE GOVERNMENT OF QATAR
IN VERGELS RECEIVED FROM THE GELLAR
REPUBLIC OF TURKEY GOVERNMENT
GOVERNMENT GOVERNMENT OF QATAR
Double-tax revenue over revenue isteðiyleto make a statement that prevents taxation
people are getting to the following:
This means that one or both of the Skit States will have a meeting. will be applied to the system.
1. This will apply to taxes on income, whether in the form of an Akili Devlette or political subdivisions, or in the neighborhood administration over income.
2. Securities and real estate assets have been overhauled. All taxes received over the total income or income items, including taxes applied, will be considered as tax from income.
3. Specifically, taxes that apply to this implementation are available in particular:
a) in 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");
b) on the State of Qatar:Taxes received over
(This will refer to as "Qatari tax").
4. The statement adds to current taxes after the date of signing of Or they will be applied to taxes that are identical to or substantially similar to existing taxes, rather than in their place or in their place of duty. The competent authorities of the Aşit States will report to each other the important depositions made in the applicable tax legislation.
1. From the purposes of this task, unless the text is predicted to the contrary:,a) i) the term "Turkey" is the area of sovereignty that Turkey has, its territorial waters, air space, at the same time, in accordance with international law, express authority or sovereignty rights for the purposes of investigation, operation, and protection of the legal resources;
ii) The term "State of Qatar" refers to the sovereignty and sovereignty of the State of Qatar. refers to the territorial waters, including the rights of the judiciary and the rights of sovereignty, in accordance with international law; and its territorial waters, including its own rights of sovereignty;
b) "A State of Love" and the terms of the "Diyaker" State of Turkey, according to the text of the text or the State of Qatar;
c) "Kishi" refers to a real person, a company, and a lot of people. coverage of any installation;
d) " The term 'term' is treated as an institution, in terms of any institution or taxation. to any organization that sees it;
i) any real person who is a citizen of a Akkit State;
ii) any status that is a status winner based on the legislation in effect in a Akite State The government, partner or association
f) the terms of "A Devotion of the State" and the "Devotion of the other", "The Deviant of the" A request that is being pushed by a Revenue State team and a request that is being pushed by the Government of Akit, a city of the Republic of America;
g) "Authority for authority":
i) in Turkey, the Ministry of Finance or its authorized representative; and
ii) in the State of Qatar, the Ministry of Finance, Economy and Trade, or its
h) The term "internationalistic traffic" is only within the sars of the Digait State. Except for the fact that the ship, aircraft or land transmission is not deployed, the ship, aircraft or land transmission is reported to be deployed by the State of the Azoit State.
2. As a result of implementation of this statement on any date by the State, any term that is not defined in the Meaning stipulate that, unless the text is contrary to the text of the purposes of the meaning of the applicable taxes, at the time Meaning that this state will have an advantage in the current tax legislation, and this term will be superior to the meaning of this term in the other.
1. For the purposes of this statement, the term "a Instrument State" is a state, including any political subdivision or neighborhood administration, and that state is subject to the legislation of home, residence, law, central, administrative or similar to the state. For any criteria, the taxpayer is responsible for any criteria. However, this term does not include any money that is being subject to tax in that state, only because of the revenue from sources in that State.
2. The state of the following will be determined by the condition of the 1st fikra provisions, when a real person is a person in both of these Azoys.:
a) This is the state of the state where there is only a permanent permanent location Will be accepted. If this part has a permanent permanent seat in both Develes, it will be accepted by a State of the State (which is the center of vital interest) for which their personal and economic relations are closer;
b) If no State is determined to have the center of the vital interests of the Eucer person, or if there is no permanent residence in both Devlette, a cameo will be accepted for the state where the home is not only the same as the home;
c) If there is a home in both Devlet, or both, or both Devlette. If such a house is mentioned in the state, it will only be accepted by the state of the state where the citizen is concerned;
d) Eater is a citizen of both State or both Devlets If it is not, the authorities of Akit will resolve the issue with the understanding of the problem.
3. When both Sitel Devices are involved in the actual performance of the 1st fikra provisions, they will only be recognized as the machine of the Aware State where the active management location is located.
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 covered by:Yönetima) Management location;
f) Magen oasis, oil or natural gas well. any location, andany other location, and
g) an initiative, structure, or installation of 12 months in progress project.
3. Any prior provisions of this clause will be considered to include the term "workplace":
a) The facilities of the company, the property of the business, or the commercial property of the company storage, purpose, or delivery purposes;
b) store-owned goods or commercial stocks, only storage, contact, or for delivery purposes;
c) stocks of goods or commercials belonging to the country are only a form of contact. retention with the purpose of being done;
d) Do not import a fixed place, only if it is a business or commercial property or collecting information for purposes of collection;
e) a stable place is only prepared or helpful for the service. a character that is intended to be executed by any other character;
f) A fixed location is mentioned only in (a) to (e) to perform one or more of the activities together; however, performing these activities together will result in the preparation or performance of the collective action that shows itself as a result of performing.
4. In a case where the 1st and 2nd fikra provisions are removed, a team of people will act on behalf of a state of the service in an event that will be applied to the name of the State of 5 and have the authority to fend for this contact. If it uses its authority from the mutaden, the activity of the business in question is not in the case of the third party, as it is not in a fixed place, but with any activities that did not make this place a place of place. It has a business in this state with all kinds of activities that it has made for us. will be accepted.
5. An Akit State community is a state in which it conducts its business in a state of emergency, a general commission agency, or any agency that is not alone in the status of a team of agents. The owner will not be accepted as a replacement.
6. A company that is a member of the State of a âite, has control or is controlled by a company that is the member of the State of the World, or in a commercial activity (in a workplace or other way) in this state, if controlled by it. Any one of the companies will not have an office space for the other.
RESULTING FROM GAYRISECURITIES
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" contains the value of the entity in which it is found will be defined according to the legislation. 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. will cover the rights of the indent rights and mines, resources and other real estate, or rights over payments, whether ships, vapes, and aircraft are considered to be real estate assets. will not be tolerated.
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 income derived from real estate assets used in the invention of the free business activities.
1. The gain of a Profitable State government will be taxed only in this State, as it does not engage in commercialized activity in the case of the telemarkeet, in the case of the teleport, the Turkish in the country. If commercial activity is found in the above mentioned commercial activity, the country's earnings may be taxed in this other state, only to be attributed to the amount that can be attributed to this business.
2. In the event of a commercial operation with a State of the Republic of Azite Azoit Devlette, a city of Azite State, to remain withheld by the provisions of the 3rd Fükra, both in the Azores and other similar conditions were made in the same way. It would be a total profit, regardless of whether it would be a complete separation of the same or similar activities, and gain a total loss of quality from the person who has been involved in the development of a place where he has been.
3. When determining a location for a business, any expenses that are appropriate for the purposes of the office, including management and general administration expenses, will be allowed to be downloaded, including management and general administrative expenses. However, discounts to be made to the main or base central expenses will not be able to take up 3% of the gross damage of the site.
4. Instead of a business, this is a business or business with a service No gain will be attributed to the receipt of it.
5. Earnings are organized separately in other items of this section. The provisions of those articles shall not be affected by the provisions of this matter.
CHECK FOR AIR AND LAND
1. Earnings from the event of a State-led government transport, aircraft or land transmission in international traffic, will only be taxed on this state.
2. Regardless of the purpose of the State of Qatar, the term aircraft refers to the Gulf Air Route as long as the term of the State of Qatar is to be held, regardless of the purpose of the State of Qatar.
3. For the purposes of this matter, an Akit State teething, the gains from the construction of ships or aircraft in international traffic, with the result of the gains imposed by the provisions of the 1st fikra as a response to the results of the will also cover the proceeds from the use or rental of containers.
4. The provisions of the 1st phase of this Article will also be applied to the proceeds of a partnership, a partner, or an agency that has been pushed into an international accuser.
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, a Âkit Government contact and The management, control or capital of the Union of Turkey, and
is either, both, or imposed or imposed on commercial or financial services between the two cities. The conditions, which must be in one of these countries, are the profits that are supposed to be in one of these countries, but they are added to the earnings of that individual, and accordingly, they are added to the benefit of the year. taxable.
2. It includes the earnings of the state's self-inclusion and tax on taxation, which is taxed in the other State of the World, and the first mentioned state of the state is the benefit of the two, the state of which the State has been taxed in. As a result of the fact that the state of this specification is in place, given the conditions that need to be made in front of the first mentioned State of the United States, the State of the United States of the United States will not be able to use the same will make the necessary corrections to the quantity. When making this corrections, any provisions of this statement will be kept in mind, and the competent authorities of the states of Aşit will be consulted.
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 were the subject of the phrase, which paid off the dividend. It may also be taxed according to the State of the State and in the legislation of this State; however, the true beneficiary of the dividend, which obtained the dividend, will not address the proportion of tax rates that will be taken in this way:
a) The true beneficiary of the dividend is the capital of the dividend payout if a company is holding at least 25 percent (except for the partners), the amount of the gross dividend is 10%;
b) 15% of the amount of the gross dividend in all other cases.
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. statements from the state of the state, which is the revenue from taxation, and revenue from the country's company, which is treated as the same as the revenue from the taxation of stocks, according to the state of the state, which is the same as the fund and the preoccupation of the business.
4. Diyer in a workplace in the state in which it is engaged in a commercial operation The winner of a Convenience Government Company, after being taxed according to article 7, may be taxed in accordance with the 2nd receipt of this article in the Akit Devlette, where this item is located through the remaining part of the city.
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. 1st and 2nd fikra provisions shall not be applied if there is an active view of this place or fixed place, if the activity is performed and the subject has obtained the dividend. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.
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. With this, this interest is achieved in the resulting Âkit Devlette and that state. It can also be taxed, but the real beneficiary of interest in interest will not waste 10 percent of the gross amount of your tax interest in this way.
3. Looking at the 2 nci fikra provisions, the one in a Âkit Devlette doklet and;
i) the Government of the Republic of America, the political subdivision, or the local government;
ii) by the Central Bank of the Devlet State of the Republic,faizleras the actual beneficiary, this is the exception of the data in this State .
4. The term "interest" used in this material is derived from all types of creditless revenue and bonds or debt, in any kind of creditless revenue, regardless of the mortgage guarantee or recognition of the debtor's earnings. refers to revenue.
5. The true beneficiary of the interest in a Âkit Government team is found in commercial activity by the entity in which the interest is obtained, or if it is engaged in business with a fixed place in the other Devlette. No provisions of the 1st or 2nd fikra shall be applied to the fact that the subject or the fixed site is active in the interest of the payment of the subject. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.
6. A State of the State itself, the political subdivision, the neighborhood administration, or the interest paid by a member of this State, will be accepted in that Akit Devlette. 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 to be obtained in the State where the location, place, or fixed location is located.
7. The amount of interest paid in return is in the actual beneficiary range with the oder Due to the special relationship that exists between both or both, the provisions of this article will only be applied to the most recently mentioned quantity, in the event that there is no such relationship, in the event that such a relationship has been agreed. 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.
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 value of the non-monetary rights in question is in the In the state and in the legislation of the state, it can be taxed, but the real beneficiary of the value of an illegitimate claim is that the tax will not waste 10 per cent of the gross amount of the cost of the gayrimaterial right.
3. The term "Gayrimaterial rights" used in this material is a literary, artistic or scientific copyright of any kind, including the bands used in radio and television broadcasts with motion picture films, any kind of patent, any kind of difference between you and the other. The use of the model, plan, secret formula or production method, or use of the production method, or any payment obtained from the financial, commercial or scientific experience, resulting in the accumulation of information.
4. The real beneficiary of the cost of an Akit State is a real beneficiary, if it is found in commercial activity with the entity in which the price was obtained, or a fixed place in this other Devlette. if professional activity is found and there is an active view of this office or fixed place with the right or the right to be paid, the 1st and 2nd fikra provisions shall not be applied. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.
5. A State of the State itself, the political subdivision, the neighborhood administration, or the amount of the diligent right paid by a member of this State, will be accepted in that Akit Devlette. 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 value of the property or fixed location will be considered to be obtained in the Fuel State.
6. The amount of the amount of money that is paid for use, rights or information, is the amount of The provisions of this article are only the most important because of the fact that there is no such relationship, because of the fact that there is no such relationship, because of the fact that there is no such relationship, because of the fact that there is no such relationship with the oddler or the actual beneficiary between both. will be applied to the last 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.
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 presence of an area owned by a Kite State community, or in a fixed place to perform free business in a ÂKit State party. Profit from the disposal of the entity 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 ship, aircraft or land transmission vassing, or ship, aircraft or land transmission vastaresses were sold in international traffic, and the proceeds from disposal of the securities related to the transport of the aircraft or land transmission are only available, according to a Turkish State-led traffic. will be taxed in this Devlette.
4. In the event of an overhaul of the remaining barrels of the L, 2, and 3, the proceeds will be taxed only in the Fuel State, which is the result of the loss. However, the capital gains from the above mentioned in the sentence above will be taxed in the other Profitable State in the event of no more than a year of economic growth, economic and overhaul.
FREE TRADE INTEREST
1. In the event that a State team has acquired free vocational activities or other activities, it has no fixed place in which it can be used to perform its activities in the first place in the future, a Turkish government said. For the process, it will only be taxed on this State. In the event that the winter has no such fixed place, the revenue can be taxed in this other state, only with the amount that can be attributed to the fixed place in question.
2. The term "free crafts", especially those executed as a case of It covers the activities of scientific, literary, artistic, literary, or other, as well as the activities of physicians, lawyers, engineers, architects, workers and accountants.
IMPOSITION of IMLIFACIALITAREDS
1. The provisions of articles 16, 18, 19, and 20 will be taxed, charged, and other such as a service indirect, in which a Service shall be taxed only in this Devlet unless the service is performed in the other's in the State of the Aper Atoll. If the service is performed on the other Devlette, then the proceeds from this 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 a calendar year related to the other Devlet, or a total of 183 days at a time of twelve months ending, and
b) Payment by an informal or non-conserved state of the other State If the issuing name is done, and
c) Payment is from a place or fixed place that the owner has in the other State If notyapýlmazsa
will be taxed only on the first mentioned Devlette.
3. The provisions of the 1 and 2 feats, a ship of the Republic of Turkey, a ship that was executed in international traffic by the other State of the Republic of Turkey, a service that was executed by the aircraft or land transmission, and a service that was executed by the State of the Republic of Turkey. Other similar revenues can be taxed in this one, in the other in the Aper Giant.
PAYMENTS TO MANAGERS
The management of a Aper Government team, a member of the Dikit's State team Fees and other similar payments that are obtained by the fact that they are a member of the board may be taxed on this other Devlette.
1. An artist, a member of the art of theater, cinema, radio or television art, regardless of the provisions of the 14th and 15th articles, performed the activities of a musician or a sportsman in the activities of the other Akit Devlette in the event of the activities of the artist. income, which may be taxed in this other Devlette.
2. The income of an artist or sportsman from the activities of the artist or the sport itself, if directed to a woman, is an artist or athlete who is not alone with the provisions of 7, 14, and 15. the Akit Devlette, which is performed by its activities, is taxable.
3. It comes from the activities of an artist or athlete performing activities in the Akit Devlette, whether the visit to this State is fully or significantly supported by the public funds of the State Department, political subdivision, or neighbourhood administration. , this will be the exception of the data in the state.
RETIREESThe provisions of the 1st section of the 19th section of
are intended to remain a Sakite State. Pensioners and similar payments paid in the past of the transition to the party will only be taxed in this State. In addition, this provision will also apply to regular payments for a lifetime of the Government of the Azoth.
1. In a case of public service to itself, the political subsection or the neighbourhood administration, the State, subsection, or administrative, fee, and other such payments, made by a real person, are the following: will only be taxed in this state, including the retired people.
2. 15, 16, 17 and 18 of the articles of article 15, 16, 17 and 18 are the provisions of a Department of State, political subdivision, or commercial operations conducted by the local government. will be applied to the system.
A citizen of the State of the State and I only know if I am in the The payments made from sources in the other state, to a student or an intern with the purpose of professional training, will not be taxed in this other Devlet from sources to the country to understand the education or professional education.
This is the earlier time that the State team has been able to do so. The factors that are not specified in their items will only be taxed in this State.
PREVENT TAX VERITABLE
1. In accordance with the provisions of the State of the Union, in accordance with the provisions of this Union, the first mentioned State would be a direct amount of income from the tax on the income of the tax on the income of the tax on the income of the tax. It will allow you to do so.
However, for the taxable income in the other Devlette, will not be able to increase the amount of income tax calculated before the mag.
2. In accordance with the provisions of the Sovereign State, in accordance with the provisions of this State, this State may also consider the exception of the proposed revenue when calculating the tax of the remaining income of this person.
1. The citizens of a State Government, in the other part of the State of America, are not able to tax or pay for taxes, especially in the direction of the United States, especially in the direction of the state, especially in the future, in particular, in the case of the State of the State. They will not be subject to a taxation and a responsibility to the public.
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.
3. One or several of the countries of the State of a âite, in which the State of the World, the government, or its wholly owned or controlled interests, is the first mentioned State of the State of the State of the State of the State. Whether they are or are not subject to taxation or otherwise, they will not be subject to taxation, or otherwise, subject to taxation.
4. These provisions will not be understood that a Government has to apply discounts, taxes, and matrah discounts to their own party and to the Government of Turkey, as well as in the case of a family of family.
BUSINESS MANAGEMENT PROCEDURE
1. A Âkit State guard, in the case of one of the following, has created or created a non-compliance tax on the provisions of one of the entities, or the provisions of these States ' internal legislation, a State of the Union address. In any case, he may present the situation to the competent authority of the State of the World, which is the case of the State. If the state of this winter complies with the 1st of the 23rd Article, then it may be possible to address the authority of the government in which it is a citizen. The acquis must be done within the time specified in the domestic legislation of the State of the United States.
2. If a satisfactory solution is not resolved with the right of an appeal, the competent authority will strive to understand the country's competent authority, in an effort to avoid a further taxation of the State of 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 deemed necessary to reach the point of understanding, this vision can be conducted through a commission of representatives of the authorized authorities of the State of Aşit.
EASY TO DEAL WITH THE BUSINESS
1. As long as the competent authorities of the State States do not have the information or the information required to enforce these provisions, the authorities 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 by the law or penalty of law or execution of the taxes specified in this statement, and this is will be given to the office or authorities (including the official authorities and administrative organizations) for looking at the concerns and objections of the matters. 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) will not comply with the legislation and administrative applications of the Keni or the other administrative measures;
b) legislation or normal administrative actions of the Keni or other submission of information that cannot be obtained within the frame;
c) To make any commercial, sanni, professional, or commercial action taken in the public export information or information about a public orderaykýrý
cannot be interpreted to put it under the obligation.
CHARGED WITH OFFICERS AND CONSULATES OFFICERS
The provisions of this statement will not affect the financial details of the officers or consular officers on the diplomat's government, which will make use of the provisions of the general rule of law or the provisions of special understanding.
The authorities of the United States have been misusing the purpose of the They may refuse to take advantage of any interest or interest in taking advantage of the interests of the business if they arrive at the point of view that the conditions of the relationship are being met.
Each of the Akit States has internal legislation to make this effective. will notify you of the completion of the required action. This means that the last of these notices will be effective at the time of the end of this statement, and the provisions of this statement are: The first day of January, followed by the current entry, will be sentenced for taxes on the first day of the taxation period.
This means that it will remain in effect until it is dissolved by the State of the Force. Each of the States can annuate by issuing an annulment of diplomatic channels at least six months prior to the end of any calendar year. In this case, the statement shall not be sentenced for taxes on the first day of January following the issuance of the annulment of the annulment, or for any taxation period that is later in place.
TEXT FROM THESE SERVICES, They signed the statement and gave up their seals, as well as the full reps.
in Turkish, Arabic, and English, from 2001 to the 25th day of December 25th Herri 1422 was held in Ankara on the 10th day of the 10th month of 1422. All three texts are equally valid. If there is no difference between the text, the English text will be valid.
TURKISH REPUBLIC GOVERNMENT GOVERNMENT GOVERNMENT GOVERNMENT
Sumer ORAL Yousef Hussain KAMAL
Finance Minister Finance, Economy and Commerce