Turkish Grand National Assembly Warning: You Are Viewing Act, The Parliamentary General Assembly Has Already Adopted. If It Does Not Include The Changes Made Later. Between The Government Of The Republic Of Turkey And The Government Of The State Of Qatar

Original Language Title: TÜRKİYE BÜYÜK MİLLET MECLİSİ Uyarı: Görüntülemekte olduğunuz Kanun, TBMM Genel Kurulunda kabul edildiği halidir. Varsa daha sonra yapılan değişiklikleri içermemektedir. TÜRKİYE CUMHURİYETİ HÜKÜMETİ İLE KATAR DEVLETİ HÜKÜMETİ ARASINDA

Read the untranslated law here: https://www.tbmm.gov.tr/kanunlar/k5513.html

Law No. 5513

Acceptance Date: 01/06/2006
ARTICLE 1, signed in Ankara on 25 December 2001 "The Government of the Republic of Turkey between the Government of the State of Qatar Agreement on Double Taxation on Income Taxes" has been used in the validation of.
Article 2 of this Act shall enter into force on the date of publication.
Ministers executes the provisions of Article 3 of this Law.

















THE GOVERNMENT OF THE REPUBLIC OF TURKEY



BETWEEN THE GOVERNMENT OF THE STATE OF QATAR THROUGH THE INCOME TAX
at
DOUBLE TAXATION AGREEMENT

GOVERNMENT OF THE REPUBLIC OF TURKEY AND THE GOVERNMENT OF THE STATE OF QATAR

income in taxes on an Agreement Desiring to avoid double taxation
Have the following agreement: Article 1 SCOPE

|| PEOPLE | this Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED


1. This Agreement, irrespective of the manner in shall apply to taxes on income in a Contracting State or its political subdivisions or local administrations.
2. Securities or including the including taxes on gains from the disposal of real estate assets, or total income all taxes imposed on elements of income, will be regarded as taxes on income. 3
. especially taxes that apply at the moment to implement this Agreement:
a) in Turkey:
i) the income tax;
ii) the corporation tax;
iii) the levy imposed on the income tax and corporation tax;
(Hereinafter referred to as "Turkish tax" will be mentioned);
b) The State of Qatar:
Taxes on income
(Hereinafter referred to as "Qatar tax" will be mentioned).
4. The agreement also after the date of signature of the Agreement in addition to or in place of their existing taxes and the same quality as existing taxes or shall apply also to substantially similar taxes. The competent authorities of the Contracting States shall notify each other of any significant changes made in their respective taxation laws. Article 3 GENERAL DEFINITIONS


1. For the purposes of this Agreement, unless otherwise defined therein shall:
a) i) the term "Turkey" Turkey's is the sovereignty, territorial sea, territorial waters, airspace, but also the study of natural resources in accordance with international law, the jurisdiction of the exploitation and conservation purpose or to have sovereign rights refers to marine areas;
Ii) "State of Qatar" means the State of Qatar's sovereign space owned and waters that has jurisdiction or sovereign rights over in accordance with international law and the continental shelf, including express their marine areas;
B) "a Contracting State" and "the other Contracting State terms, as required by the text means Turkey or the State of Qatar;
c) the term" person "includes an individual, a company and any other body which will consist of people gets covered;
d) "company", the term refers to any entity which is treated as any institution or corporate for tax purposes;
E) "national" means:
i) any individual possessing the nationality of a Contracting State;
ii) any legal person deriving its status from the laws in force in a Contracting State, partnership or association expresses
;
F) "a Contracting State" and "the other Contracting enterprise of State", respectively, operated by an enterprise and other Contracting State is operated by a Contracting State means an enterprise;
G) "competent authority" means:
i) in Turkey, the Minister of Finance or his authorized representative; and
ii) in the State of Qatar, Finance, Economy and Trade Minister expresses
or his authorized representative;
H) "International traffic" only ship performed in the other Contracting borders of the state, except aircraft or road vehicles in operation, a Contracting ship by State-owned enterprises, means transport aircraft or road vehicles operated.
2. by a Contracting State of the Agreement on the implementation at any time, any term not defined in the Agreement, unless öngörmedik otherwise, for the purposes of the taxes to which the Agreement applies, that date will have the meaning that it has in that State's legislation and a sense Situated in the tax legislation of that State, that state's superiority over other legislation shall bear the meaning given to that term. Article 4



RESIDENT 1. For the purposes of this Agreement, "a Contracting State to a resident" refers to that State, including any political subdivision or local authority, or in accordance with State regulations domicile, residence, legal head office, place of management or similar nature due to any other criterion tax means that people who are taxpayers. However, this term is only liable to tax in that State in income derived from sources in that State does not include any person.
2. When the provisions of paragraph 1 are therefore a real person either Contracting State in the resident status of the person shall be determined as follows:
a) Such person shall be deemed a resident of the State in which a dwelling may be permanent. If a person's residence can accommodate both the State as well as permanent, this is personal and that closer economic relations (center of vital interests) will be considered a resident of the State;
B) If the person's center of vital interests is contained by the state determined, or at either State or a residence can be permanent, he shall be deemed to State a resident of the house where the habit to remain;
C) If you have a habit of staying in the house where the person in either State or both States, if not in such a house is concerned, it shall be deemed a resident of the State of which he is a citizen;
D) if he is a citizen of both States or is not a citizen of both States, the competent authorities of the Contracting States shall settle by mutual agreement. 3
. so when the provisions of paragraph 1 a person other than an individual is a resident of both Contracting State also, that person will be accepted only as a resident of the Contracting State in which its place of effective management. Article 5 1


OFFICE. For the purposes of this Agreement, "permanent establishment" means a fixed place of business is wholly or partly carried out the work of an enterprise.
2. "Commercial" refers specifically to encompass the following:
a) a place of management;
B) Branch;
C) The Bureau;
D) plant;
E) a workshop,
f) a mine, an oil or gas well. a quarry or any other place of extraction of natural resources, and
g) in a 12 month period in excess of an ongoing building site, construction or installation project. 3
. This article Notwithstanding the preceding provisions of "permanent establishment" following of the term shall be deemed to include:
a) the maintenance of facilities, only the storage of the enterprise's goods or merchandise, used for the purpose of display or delivery;
B) the maintenance of a stock of goods or merchandise only storage, display or delivery of retention;
C) the maintenance of a stock of goods or merchandise, solely for the purpose of processing by another enterprise;
D) for a fixed place of work, the only attempt to purchase goods or merchandise or held for collection of information;
E) for a fixed place of work, with only a preparatory or auxiliary character for the enterprise, held for the conduct of any other business;
F) for a fixed place of work, only (a) to (e) is held together to perform one or more of the activities mentioned in subparagraphs; however, the overall activity of a preparatory or auxiliary character must be manifested as a result of the execution of these activities together.
4. 1 st and 2 nd connected with the provisions of paragraph Notwithstanding, where a person - 5 moves an agent on behalf of the exception in a Contracting State an undertaking of an independent status to apply the paragraph and is with the name of the enterprise contract conclude agreements if it uses this authority usually, these people's activities, 3 in case mentioned in the third paragraph and to work for a fixed place of business unless limited activities in nature that make this place work, this undertaking any activities carried out for the enterprise that person would therefore be deemed to have a permanent establishment in that State.
5. A Contracting State in the other Contracting State in the business only a broker who in the ordinary course of their business, because it carries through a general commission agent or independent status of any other agency shall be deemed to have a permanent establishment in that other State.
6. a company which is a Contracting State to a resident of the other Contracting States which resident or the other State in which commercial activities (whether through a permanent establishment or otherwise) if a company checks or controlled by him, any of these companies will create a permanent establishment of the other. Article 6

INCOME OBTAINED FROM REAL ESTATE ASSETS
of
1. Income derived from immovable property situated in the other Contracting State a resident of a Contracting State (including income from agriculture or forestry) may be taxed in that other State.
2. "Immovable property", the term shall be defined according to the legislation of the Contracting State in which the assets. Terms in any case, property accessory to immovable property, agriculture (fish including breeding and cultivation) and tools used in agriculture and forestry, rights related to real estate property will be applied to private law, real estate usufruct rights and mineral deposits, sources and other natural resources at an operation or operating rights born to include rights over fixed or variable payments; ships, boats and aircraft shall not be regarded as immovable property. 3
. The provisions of paragraph 1, the direct use of immovable property shall apply to income derived from the letting or use in any other form.
4. 1 st and 3 rd paragraph shall also apply to income derived from immovable property used for the performance of independent personal services. Article 7 BUSINESS PROFITS


1. The profits of a Contracting State, through a commercial establishment situated in the other Contracting State unless the enterprise workplace shall be taxable only in that State. If the enterprise carries on business as aforesaid, the profits of the enterprise to be limited only by the amount attributable to that permanent establishment may be taxed in that other State.
2. Paragraph 3 Without prejudice to, if a Contracting State on business through a permanent establishment situated in the other Contracting State, each Contracting State in earnings will be attributed to this work, this work under the same or similar circumstances, located in the same or similar activities completely separate and If an individual were to gain a completely independent nature of the enterprise and the enterprise create a workplace that is what will be earning a profit by the same amount. 3
. In determining the profits of a permanent establishment, made in the State in which the permanent establishment is situated, or in any other place, including management and general administrative expenses, it shall be allowed as deductions expenses which are incurred in accordance with business objectives. However, the main or main office expenses discounts to be made in the participation of the workplace, the workplace shall not exceed 3% of gross revenue.
4. Office of the mere purchase of goods or merchandise for the enterprise business will therefore by no attributable profit.
5. Earnings receives the scope of income elements arranged separately in other Articles of this Agreement, the provisions of those Articles shall not be affected by the provisions of this Article. Article 8

SEA AND AIR taşımacıllg the
1. ships in international traffic of a Contracting State, the profits derived from the operation of aircraft or road vehicles shall be taxable only in that State.
2. Notwithstanding the provisions of Article 1 of this Agreement, the State of Qatar in terms of the purposes of the preceding paragraph, as long as the term of the State of Qatar aircraft to Gulf Airlines shares refers to the company. 3
. For the purposes of this article, a Contracting State enterprise of the gains obtained from ships or aircraft in international traffic, paragraph 1 to use the containers provided to obtain as incidental to the profits to which it applies or gains derived from the rental will include.
4. The provisions of paragraph 1 of this Article the same time, a partnership, a joint venture will be applied or an international operating agency to profits from the participation. Article 9 ASSOCIATED ENTERPRISES


1. a) a Contracting State participates directly or indirectly in the management of the other Contracting State, when he joined, control or capital; or
b) the same persons participate directly or indirectly in the management of a Contracting State in the other Contracting State, when he joined, control or capital and
in both cases, which occur in commercial or financial relations between the two undertakings or imposed conditions which would be made between independent enterprises when those conditions, it should be in one of the undertakings, but for those conditions so accrued, may be included in the profits of that enterprise and taxed accordingly.

2. A Contracting State includes in the profits of an enterprise gains taxes, include the gain of other state enterprises which are taxed in the other Contracting State and earning at the same time grasp the first-mentioned State, taking into account the conditions that must exist between the two undertakings, if the conditions mentioned State made calculations that earnings determined as a result of other If the government considers that this designation is in place, it will make the necessary adjustment to the amount of taxes on those profits in question. This adjustment, will be taken into consideration other provisions of this Agreement and shall consult the competent authorities of the Contracting States when required. Article 10 DIVIDENDS


1. Dividends paid to a resident of the other Contracting State by a company which is a resident of a Contracting State, may be taxed in that other State.
2. However, such dividends may be taxable in the company paying the dividends is a resident of that Contracting State and according to the laws of that State; but dividends if the beneficial owner of the dividend has been achieved, the tax so charged shall not exceed the following rates:
a) the beneficial owner of the dividend, dividend paying company's capital directly at least 25 percent of the company holding (other than a partnership) Dividend gross 10 percent of the amount;
B) 15 per cent of the gross amount of the dividends in all other cases. 3
. This article used "dividends" means income from shares, the dividend shares or jouissance rights, according to ensuring the participation in profits is not in the nature of the founders' shares or debt to income derived from other rights distribution companies of the State of the legislation is a resident, but the income derived from the shares for tax purposes investment is treated as income from other corporate rights obtained funds and refers to income derived from investment trusts.
4. The other Contracting State in a Contracting State companies with commercial activities through a permanent establishment situated therein, after having been taxed under Article 7, the remainder through the workplace to the Contracting States 2 of this Article be taxed in accordance with paragraph.
5. the beneficial owner of the dividends is a Contracting State, with the event if the dividends paid by companies resident that carries on business through a permanent establishment situated in the other Contracting State, or if the execution of the self-employed activity by that other State situated at a fixed location and of acquiring such dividends such permanent establishment or It is effectively a link between fixed locations, paragraphs 1 and paragraph 2 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply. Article 11 INTEREST


1. Arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in that other State.
2. However, such interest may also be taxed in the Contracting was obtained by the State and that State's legislation; but if the beneficial owner of the interest rate you get, the gross amount of the interest the tax so charged shall not exceed 10 per cent. 3
. Notwithstanding the provisions of paragraph 2 arising in a Contracting State and;
i) The Government of the other Contracting State, a political subdivision or local authorities of;
ii) the Central Bank of the other Contracting State, the interest obtained
real beneficiaries will be exempt from tax in that State.
4. This article is used in the "interest" means, whether or not connected to the mortgage guarantee or borrower you know you recognize their right to participate in the profits, revenue arising from claims of every kind, and particularly refers to revenues derived from government securities, bonds or debentures.
5. the beneficial owner of the interest is a Contracting State, if no commercial activity by the other Contracting State through a permanent establishment situated is obtained of the interest or between is found in professional services by that other State situated at a fixed location and to receive payment of such interest that permanent establishment or fixed base effective bulunmaktasy ties to, or paragraph 2 of Article 1 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.
6. A Contracting State or a political subdivision, a local authority or the interest paid by a resident of that State, he shall be deemed to arise in the Contracting State. However, the person paying the interest, whether a Contracting State to a resident or not, has in a Contracting State is a permanent establishment in connection with which the indebtedness on which the interest payment or a fixed base and such interest is borne by such permanent establishment or fixed base, then such interest, establishment or fixed base State which shall be deemed to arise.

7. The amount of interest paid in exchange for receivables from real beneficiaries payer or because of a special relationship with any other person with both, exceeds the amount which would have been agreed such in the absence of the relationship payer and the beneficial owner, provisions of this Article shall apply only to the last-mentioned amount. In this case, an additional payment, taking into consideration other provisions of this Agreement shall be taxable according to the laws of each Contracting State. Article 12 of


ROYALTIES 1. A Contracting State arising in the other Contracting State and paid to a resident of intangible royalties, may be taxed in that other State.
2. However, they obtained in the Contracting State in which it said royalties are taxed according to the state legislation; but they get the royalties, if the beneficial owner of the royalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. 3
. This article is used in "royalties" to the term, movies and literature, including tapes used for radio and television broadcasting, artistic or scientific of all kinds of copyright, of any patent, trade mark, design or model, plan, secret formula or process or industrial use or right to use any covers payments obtained in exchange for commercial or scientific experience-based knowledge.
4. the beneficial owner of the royalties is a Contracting State, if carries on business through a situated in the other Contracting State in which he obtained such price workplace or is found in self-employed activities by that other State situated at a fixed location and workplace rights or assets that paid such price or is effectively a link between fixed locations, paragraphs 1 and paragraph 2 shall not apply. In this case, Article 7 or Article 14 as the case may be, shall apply.
5. A Contracting State or a political subdivision, a local authority or of the royalties paid by a resident of that State, he shall be deemed to arise in the Contracting State. However, paying the royalties person, you get a Contracting State to a resident or not, when a Contracting State in royalties to a permanent establishment in connection with which the right or property giving rise to payment or a fixed base and the royalties are borne by such permanent establishment or fixed base, such royalties fee, shall be deemed permanent establishment or fixed base is obtained in the Contracting States.
6. Use the amount of right or information for royalties paid in exchange for royalties, between the beneficial owner and the payer or the reason of a special relationship with any other person with both, if the payer in the absence of such a relationship exceeds the amount to be agreed between the real beneficiaries of these provisions are only the most It shall apply to the last-mentioned amount. In this case, an additional payment, taking into consideration other provisions of this Agreement shall be taxable according to the laws of each Contracting State. Article 13 CAPITAL GAINS


1. Mukîmîne of a Contracting State, situated in the other Contracting State, and Article 6 of the gains derived from the alienation of immovable property referred to, may be taxed in that other State.
2. Gains from the alienation of movable property of a permanent establishment of the commercial estate assets, including the assets or a Contracting State residents used to perform a self-employed activity in the other Contracting State a fixed place owned by a Contracting State in the other Contracting State, this establishment (alone or with the whole enterprise together ) or including gains from the disposal of fixed base, may be taxed in that other State. 3
. A Contracting State enterprise of ships or aircraft operated in international traffic, aircraft or road vehicles or such ships or aircraft derived from the alienation of movable property pertaining to the operation of transport means the gains shall be taxable only in that State.
4. l, 2 and 3 in paragraphs gains from the alienation of any property other than those specified, shall be taxable only in the Contracting State of which he is a resident of the disposal of. However, the above mentioned sentences and capital gains derived by the other Contracting State, if it does not exceed a period between acquisition and disposal of the other Contracting State may be taxed in the year. Article 14 Independent Personal Services



1. Of a Contracting State residents, self-employed activities or income derived by other activities of an independent character, that person unless there is a fixed constant that can be used locations in order to perform their activities in the other Contracting State shall be taxable only in that State. People's income when it has such a fixed base, only to be limited to the amount attributable to such fixed base, may be taxed in that other State.
2. "Professional services" includes especially independent scientific, literary, artistic, educational or teaching activities, as well as doctors, lawyers, engineers, architects, dentists and the independent activities of accountants. Article 15 1


BAĞIMLIFAALİYET on. 16, 18, 19 and Article 20 of the provisions for a service due to salary received by the Contracting State resident, fees and other income, this unless the employment is exercised in the other Contracting State shall be taxable only in that State. If the services are rendered in that other State, the said income derived therefrom may be taxed in that other State.
2. 1 Notwithstanding the provisions of paragraph, a Contracting State a resident of the income derived by a service exercised in the other Contracting State if:
a) persons who generate revenue, the other States in the beginning of the calendar year or ends in any twelve-month period a or if not to exceed a total of 183 days on several occasions, and
b) Payment, if the other State resident by a non-employers or on behalf of an employer, and
c) payment of a permanent establishment which the employer has in the other State or a fixed base
do not be taxable only in that State. 3
. 1, and notwithstanding the provisions of paragraph 2, a Contracting State Mukîmîne of the other Contracting State is operated from a ship in international traffic, aircraft or road vehicles in the performance is a service thus obtained salaries, wages and other income taxed in that other Contracting State.
Article 16 PAYMENTS MADE BY A DIRECTOR

resident of a Contracting State, a resident of the other Contracting State that fees charged by the company's board members and other similar remuneration derived by a couple, may be taxed in that other State. Article 17


SANATÇIV to SPORTSMEN 1. 14 and Article 15 Notwithstanding the provisions of a Contracting State with theater, cinema, radio or television artist, an artist as a musician or an athlete in the other Contracting State exercised in the income from his personal activities, that other State may be taxed.
2. An artist or income in respect of personal activities as athletes exercised not to the entertainer or sportsman himself but to another person, that income 7, 14 and bound by the provisions of Article 15 notwithstanding the artist or taxed in the Contracting State in which the performance of the athlete's activities. 3
. income derived from activities as an artist or sportsman Contracting State exercised this visit State made in whole or significant other Contracting State, a political subdivision or local authority thereof is supported by public funds shall be exempt from tax in that State.
Article 18
PENSIONS
Article 19 paragraph 1 of the provisions of the salaries, pensions and other similar remuneration paid in consideration of past employment in a Contracting State a resident shall be taxable only in that State. These provisions also apply to a resident of a Contracting State also provided regular payments for life. Article 19 GOVERNMENT SERVICE


1. A Contracting State itself, and therefore a public task to a political subdivision or local authority in respect of services rendered by an individual, this state salaries made by or subdivision or authority, wages and other similar remuneration, including pensions shall be taxable only in that State.
2. A Contracting State or a political subdivision or local authority in return for services rendered in connection with a business carried on by salaries, wages and other similar remuneration and pensions of 15, 16, 17 and Article 18 shall apply.
Article 20
STUDENTS
who are nationals of a Contracting State and the other Contracting State solely for education or a student or apprentice who for the purpose of vocational training, payments from sources outside the other State to meet the education or training, in that other State shall not be taxed. Article 21

They DİĞERGEL

Resident of a Contracting State, where you were born is born, not dealt with in the foregoing provisions of this agreement shall be taxable only in that State. PREVENTION OF DOUBLE TAXATION Article 22


1. A Contracting State when the provisions of this Agreement in accordance with achieved an income that can be taxed in the other Contracting State, the first-mentioned State that resident from the tax on the income, will be allowed to deduct an amount equal to the income tax paid in that other State.
However, such deduction to taxable income in the other State shall not exceed the amount of income tax computed before the deduction.
2. in accordance with the Agreement of a Contracting State a resident of the event to earn an income that is exempt from tax in that State, that State, such resident, in calculating the tax on the remaining income, take into account the exempted income. Article 23 1


AYRIMYAPIL not. Of a Contracting State citizens of the other Contracting State, that other State of the citizens in the same circumstances to any taxation staying or face and the associated liabilities, especially in terms of residency will be subject to different or more burdensome than the taxation and related obligations.
2. Article 10 of paragraph 4 of the provisions for an establishment which has in the other Contracting State of a Contracting State, the other States, according to the other State undertakings carrying on the same activities will be faced with less favorable taxation. 3
. A Contracting State by the other Contracting State by one or more residents, directly or indirectly, totally or partially owned capital or controlled enterprises, in the first-mentioned State to any taxation they are or may be subject to other similar enterprises of that State or different from the related liability or heavier they will be subject to taxation and related obligations.
4. These provisions, a Contracting State to a resident of his own personal allowances due to personal or family circumstances apply, the tax base and discounts will also have to understand the direction that the resident of the other Contracting State. Article 24 Mutual Agreement Procedure


1. A Contracting State when the Contracting Giant! Meat from one or both of the operations for which he created a tax that falls in accordance with the provisions of this Agreement or will the conviction, regardless of the remedies provided by the domestic law of those States, the state of the Contracting State is a resident of the competent authority. If this person's condition in accordance with article 23 paragraph 1 fall, then citizens may apply to the competent authority of the Contracting State of which he is. The application in question must be made within the period specified in the domestic law of the Contracting States.
2. The competent authority shall endeavor, if the objection is justified and if he can not reach a satisfactory solution, in order to prevent a taxation contrary to the agreement, will endeavor to mutual agreement with the competent authority of the other Contracting State. 3
. The competent authorities of the Contracting States, any difficulties or doubts arising as to the interpretation or application of this Agreement shall endeavor to resolve by mutual agreement. The authorities at the same time, resulting in cases not provided for in the Agreement may also consult together for the elimination of double taxation.
4. The competent authorities of the Contracting States may communicate directly with each other to reach agreement on the issues specified in the preceding paragraph. When the verbal exchange of views deemed necessary for reaching an agreement, these negotiations may be conducted through a Commission consisting of representatives of the competent authorities of the Contracting States.

Article 25 EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting States, as long as the mismatch with the knowledge or agreement necessary for the implementation of the provisions of this Agreement, the information will hold subject to changes that are necessary for the implementation of domestic legislation on taxes covered by the Agreement. Any information received by a Contracting State, that State of the information obtained under the domestic legislation will be kept confidential and as such only the accrual of tax specified in this Agreement or charged or forced the enforcement or punishment, and to deal with complaints in these matters and appeals officers persons or authorities (judicial including authorities and administrative bodies) can be given. Such persons or authorities shall use the information only for such purposes are concerned. These persons or authorities may disclose the information in public court proceedings or in judicial decisions.
2. The provisions of paragraph 1, in no way a Contracting State:
a) to carry out administrative measures at variance with that or the other Contracting State legislation and administrative practice;
B) to supply information which is not obtainable under the laws or that or the other Contracting State the normal administrative procedures;
C) Any commercial, industrial, or professional secret or trade process, which makes public information or publicity not falling contrary to public order
obligation can not be interpreted to be put under.



Article 26


diplomatic agents and consular officers provisions of this Agreement, under the general rules of international law or the provisions of special agreements on diplomatic agents or consular officers shall affect the fiscal privileges.
Article 27 LIMITATION
INTERESTS The competent authorities of
Contracting State in which the Agreement, the aim of the conditions of that abuse occurs if they reach a consensus, may reject any person or process to benefit from the benefits provided by this Agreement by mutual agreement. Article 28


ENTRY INTO FORCE Each of the Contracting States, this Agreement is completion of the procedures necessary for the entry into force of the domestic law will be reported to the other. This Agreement, these notifications the date of receipt of the latter will enter into force and the provisions of the first day of January of the year following the Agreement's entry into force or later shall take effect for annual tax for each tax period. Article 29


Termination of this Agreement shall remain in force until terminated by a Contracting State. Each Contracting State, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year may terminate this Agreement. In this case, the agreement, the first day of January of the following year or to give notice of termination shall not be valid for the later starters tax for each tax period.
IN WITNESS WHEREOF the undersigned, duly authorized representatives of the undersigned, have signed this Agreement and have already laid down their seal.
Turkish, Arabic and English languages, in late November 2001, corresponding to the 25th day of the 10th month of the Hijri year 1422 was organized in Ankara on 10th day. All texts are equally valid. In case of differences between the texts, the English text shall prevail.

STATE GOVERNMENT OF THE REPUBLIC OF TURKEY FOR THE GOVERNMENT OF QATAR
ON BEHALF OF ON BEHALF
Sümer Oral Yousef Hussain KAMAL
Minister of Finance, Economy and Trade
Minister