The Turkish Grand National Assembly Warning: You Are Viewing The Law, Parliamentary General Assembly Accepted. If It Does Not Contain Any Changes That Are Made Later. The Republic Of Turkey And The Republic Of South Africa Comes From Above

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 İLE GÜNEY AFRİKA CUMHURİYETİ ARASINDA GELİR ÜZERİ

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TURKISH GRAND MULLET

Warning: The Law you are viewing is considered to be accepted at the General Assembly of the TBMM. It does not contain any later delics if it exists.


IT IS APPROPRIATE FOR THE TURKISH REPUBLIC TO APPROVE THE DECISION TO PREVENT THE SMUGGLING OF TAX EVASION AND PREVENTION OF TAX ON DATA RECEIVED FROM THE SOUTH AFRICAN REPUBLIC.  THE LAW.

Kanun No. 5484

 

Accepted Date: 6/4/2006      

 

MADDE 1- Signed in Pretoria on 3 March 2005 It is appropriate to approve the Avoidance Of Double Taxation and Preventing Tax Evasion from the Republic of South Africa in the Land of the Republic of South Africa.

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

REPUBLIC OF SOUTH AFROKKA

RECEIVED ON ARRIVAL

UNFILE DATA ON DATA PREVENTION

AND AVOID SMUGGLING VERGUS

UNDERSTANDING

 

 

REPUBLIC OF TURKEY

AND

REPUBLIC OF SOUTH AFROKKA

 

Tax revenue over Revenue with the desire to make a statement that prevents double taxation and prevents tax evasion

ADD TO FEBRUARY MEANING:

 

Clause 1

CAPACITY COVERED

This means that one or both of the Skit States will be applied to the people.

Article 2

KAVRANAN VERGALS

1. This will apply to taxes on income from the State or political subdivisions or neighborhood administrations, regardless of how much it has been taken.

2. Total revenue or revenue items, including taxes levied on the total amount of fees or salaries paid by the securities and taxes imposed on earnings from the transfer of real estate or real estate assets. all taxes will be considered as tax from income.    

3. Specifically, taxes that apply to the deal are applicable:

a) in South Africa:

i) normal tax;

ikinciii) the second tax received from companies; and

iii) withholding tax due to non-diligent rights costs;

(This will refer to as "South African tax");

b) in Turkey:

i) income tax;                                                   

ii) corporate tax; and                                      

iii) the share of funds received over income tax and corporate tax;

(This will refer to as "Turkish tax").

4. At the same time, it will also apply to taxes that are identical to or substantially similar to existing taxes after the signature date of the statement, or rather than the current taxes. The competent authorities of the Aşit States will report to each other the important depositions made in the applicable tax legislation.

Clause 3

GENERAL DEFINITIONS

1. From the purposes of this task, unless the text is predicted to the contrary:

a) i) the term "South Africa", the Republic of South Africa, and the In terms of use in the manner in which the country uses its territorial waters or jurisdiction, South Africa, which may be determined or determined in accordance with international law, which remains in its territorial waters, including its territorial waters, represents a field;

ii) The term "Turkey" is the sovereignty area of Turkey, its territorial waters, whether the rights of the judiciary or the sovereignty rights are used in order to search, operate, protect, and manage resources in accordance with international law,sýra

b) The terms "A State" and "State of the Union", the text is required  , refers to South Africa or Turkey;

c) The term "tax" is any kind of avant in the 2-ci clause of this tax means;

d) The term "Kishi" is a real match, a company and a team of people. It covers any installation;

e) the term "February", any institution or taxation entity. to any installation that is treated as;

f) refers to the term "Kanuni main center", Turkish Commercial Code or South Africa Registration of registration according to the provisions of the laws of the Code comes to the center meaning;

g) The term "Citizen":

i) any real person who is a citizen of a Âkit State;

ii) any status that wins a status according to the legislation in effect in a Akite State a legal entity, a partner, or association

refers to;

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) "Authority for authority":

i) in South Africa, the South African Revenue Service Authority an authorized representative; and

ii) in Turkey, the Finance Minister or its authorized representatives

refers to;

j) The term "internationalistic traffic" is only known as the State of the World. statements made by the ship or aircraft, except for the operation of a ship or aircraft, except for the execution of a ship or aircraft that was actually made.

2. As a result of implementation of this statement on any date by the State, any term not defined in the Meaning stipulate that unless the text is contrary to the contrary, the applicable taxes will be performed at the time of this state's instrument. 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" is a state, including any political subdivision or neighborhood administration, when the state is subject to the legislation, the residence, the residence, the central (record center), the administrative place, or the Any criteria similar to any other criteria will result in a significant amount of money for the taxpayer. However, this term does not include any money that is held in taxes only because of the revenue generated from the sources in that state.

2. The state of the following will be determined in the case of the first of the 1st storm provisions, as well as the actual performance of both Sat Devices:

a) This is the state of the state where a home is only permanent. Will be accepted. If there is a home in which both Develes remain permanently, it will be regarded as the muchas of the state, where only their personal and economic relations are closer (the centre of vital interest);

b) If only one substitute cannot be determined when the provisions of the Eyer (a) are not determined; this the state of the state will be accepted if the home is not only the last time;

c) If there is a home in both Devales of the Eucer. or if such a house is mentioned in both Devlette, only the government of the state of which it is a citizen will be accepted;

d) Both Devlets are citizens of both State or both State If it is a citizen, the authorities will resolve the issue of the authorities in the case of the authorities.

3. A person in the real world will agree to the policy of the effective administration in which the effective administrative place is found, in which case the 1st of the pearl provisions are made of the party. However, in the case of the effective administration in this part, the competent authorities of the countries in the city of Akili Devlette have the main centre, the competent authorities of the Republic of Turkey. They will be able to determine which state of the business is considered to be the part of the purpose of the deal.

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) Atele;

f) Maden oasis, oil or natural gas well, hot water or natural gas any location where resources are located;

g), a 12-month-long initiative, construction, assembly, assembly or the installation project or the surveillance activities related to them.

3. Any prior provisions of this Article will be considered to be covered by the term "workplace":    

a) The facilities of the company, the property of the business, or the commercial property of the company  be used only for storage, purpose, or delivery purposes;

b) Only storage of stock-owned goods or trade-stocks, whether to achieve with the purpose of delivery or delivery;

c) Stock-related goods or commercial stocks, only one bareka If it's a contact

eldeto be achieved with the purpose of the job;

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) for a fixed location, only in (a) to (e) It is retained to conduct a few of the mentioned activities; however, it is important that the activity is prepared or helpful as a result of the execution of all of these activities at the fixed site.

4. One of the provisions of the 1st and 2nd feats, a part of the emergency -5, acts on behalf of a government and has the authority to act on behalf of a foreign bus, as a result of the implementation of the 5th and 2nd. If using this authority, the activities of this person will not be available, as long as it is not in accordance with the activities described in the 3rd fund and which do not place this place according to the provisions of this fikra, if the company is made of a fixed location. This is Devlette, any activity that this person has made for the United States. It will be considered to have a location.

5. In a State of the Union address, the other State of the Union, in the event of a State of the Republic of America, has committed to a state of emergency, general commission agency, or any other agency that has status as its own, said in a statement that the state is running. The owner will not be accepted.

6. 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" is the one in which you have a It will be defined according to the legislation of the state. The term is, in any case, the right to real estate, agriculture (including balm production or its ability), and the equipment used in the forestry, and the right to real estate ownership of the provisions of private law, the term is not a will cover the rights of real estate and the rights of the mine quarrying, resources and other sources, or on fixed or current charges that are not available. Ships, vapurs and planes 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 fikra provisions will also be applied to income from real estate assets used in real estate from the real estate entities, as well as income from a real estate entity.

Clause 7

FINANCIAL GAINS

1. The acquisition of a Profitable State government will be taxed only in this State, as it does not engage in commercial activity in the case of a member of the telemarkeet, Akier Devlette. If commercial activity is found in the above mentioned business, the profits of the country may be taxed in this other state, with only the amount of money that can be attributed to the 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 different kind of gain, regardless of whether it would be a fully qualified person, with a separation of the same or similar activities, and a qualification that would have been completely different from the person who had been involved in the event.

3. When determining a location, you will be allowed to download expenses that are appropriate for the purposes of the site, including management and general administration expenses, that are located on the site of the state or state where the location is located.

4. 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.

5. The provisions of this provision will not be affected by the provisions of this clause, as the benefit includes elements of income that are organized separately in other items of this statement.

Article 8

DENY AND AIR OVERFLOW

1. The gains from the government of a Akkit Government for shipping to international traffic will be taxed only in this state.

2. For the purposes of this Article, the gains from the construction of a Profitable State Community in international traffic from the ship or aircraft construction, with the resulting gains in response to the gains imposed by the 1st fikra provisions:

a) the number of ships or planes used in international traffic the benefits from renting,

b) obtained from the use or lease of containers They will also cover earnings.

3. The 1st frikra provisions will also be applied to a partner, a partner, a partner or an agency that operates an international agency, as well as an agency.

Article 9

SUPPORTED CONTACT

1. a) The management, control or capital of the Minister of State, or indirectly, in the management, control or capital of the Government of Azite, or

b) The same as the same, or indirectly, the state of the State's contact and in the management, control or capital of the Diyakite State community, as well as the

and both, both commercial or financial services between the two teas, or Due to the conditions under which they must be caused by conditions, the gain that is not self-shown in one of the people due to the conditions of which they should be, is added to the earnings of that loan and are not shown in the future. It 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 necessary conditions are held in the case of the first mentioned State of the State of the State of the United States of the State of the United States of the State of the United States of America. 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 of Akif, a company that is paid by 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 the state, but the true beneficiary of the dividend, in which case the state of the State of Turkey, 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 a company holding a small 25 percent (except for the partner) is 10 per cent of the amount of the gross dividend;

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. According to the state of the government, which has received the same treatment as the proceeds from taxation, the proceeds from the Turkish direction fund and yacht association with the proceeds of the same treatment as a result of the transfer of the same treatment as the proceeds from the company's company. The revenue is expressed.

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 that the 2nd of this Article has been found over the remaining part of the article in the company's possession of the 2nd. Taxable in accordance with your own.

5. The true beneficiary of the dividend, which is a Combat State, is if commercial activity is found in the commercial activity of the company that pays the dividend, or it is a fixed place in the state of the state. 1 st and 2nd fikra provisions shall not be applied if they are found in the activity and have a significant view of this place or fixed place, with the fact that it has obtained the subject matter. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

6.   In order to retain the 4th Fükra provisions, a company with a State of the Republic of America acquired profit or income in the other State of the Union, and this is the result of the provision of payment for one of its own mutilations or obtaining dividend. No taxes can be obtained by this company, except for the status of an office in a state or a fixed site, except for the status of an active person. In the same way, this state cannot receive a non-profit tax on the non-imposed 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 Aper State and the other in the Devlet State 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, in which case the real beneficiary of interest is the tax, the tax will not increase 10 per cent of the amount of interest of the interest.

3. 2 see the ncr provisions:

a) to the government of the Republic of Turkey and the Republic of Turkey in South Africa The interest paid to the bank or the Turkish Eximbank will be exempted from the South African tax;

b) in Turkey and the Government of South Africa or the South African Central The interest paid to the bank will be exempted from the Turkish tax,

4. The term "interest", used in this material, is the result of public securities and mortgage guarantees, whether the recognition of the right to bear, bond or debt bonds, and income from any kind of creditless income. Tax legislation refers to all the revenue that is counted as an income from the rate.

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 provisions of the 1st and 2nd fikra shall not be applied. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

6. The interest paid by the perpetrator of a State of the State will be accepted in that State. However, the interest-paying person 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 the credit is due to the fact that there is no such relationship, due to the fact that there is no such relationship, because of the actual beneficiary between the payable or both, or both, and the amount of money that is not. On the other hand, these provisions will only apply to the most recent amount of the mentioned quantity. In this case, the additional payment will be taxed according to the legislation of each of the Azoys, under consideration of the other provisions of this statement.                                         

Article 12

COST-OUT-OF-RIGHTS

1. The cost of an invigorate value, which is paid to a member of the Aper State and in the other, is taxed on this other Devlet.

2. However, the cost of monetary rights may be taxed according to the legislation of the Atkit and the State of the State, but the true beneficiary of the cost of the purpose of the real estate is the tax which will be taken in this way, according to the state's legislation. It will not waste 10 per cent of the gross amount of the cost of the cost.

3. The term "Gayrimaterial rights" used in this material is a literary, artistic or scientific copyright, including radio and television records, as well as any kind of patent, any kind of patent, a pattern, or a model, a plan, a secret. use of the formula or production method, the right to use or sell the right, commercial or scientific experience, or use of the site, commercial or scientific equipment, or use of the product or use of scientific equipment. Refers to any payment that is made.

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. The value of the amount of money that is paid for by the Government of a Profit Government will be accepted in that State. However, the person who pays the price for diligent is either a member of the State or not, or has a fixed place, or a fixed place, with the right or the heir to pay the price of an artifical rights in the State of the Endeavor. If the claim is due to this location or fixed place, the value of the property or fixed location will be considered to be obtained in the State of the country.

6. The amount of the amount of money that is paid in terms of use, right or information is real, because of the fact that there is no such relationship between the other and the actual beneficiary between the other or both, because of the special relationship that exists between both and one person. The amount of material provisions will be applied only to the most recently mentioned quantity, in the amount that will be determined in the dialeddar. In this case, the additional payment will be taxed according to the legislation of each of the Azoys, under consideration of the other provisions of this statement.

Article 13

CAPITAL DEARABLE EARNINGS

1. Earnings per share of the real estate entities, which are included in the 6 ncu clause, are taxable in this State of the Republic of Turkey.

2. Securities that are owned by the commercial entity, including the commercial entity of a Kite State team, including the commercial entity, or in the case of a Âkit State party to perform free business in the Aper Transfer State. Proceeds from the disposal of the assets may be taxed in this other State, including the benefit of this location (either with or with all contact), or from the disposal of the fixed site.

3. Earnings from the disposal of securities related to the operation of the ship or aircraft, or aircraft or aircraft that were pushed in international traffic, will only be taxed in the Azite State where the interest is due.

4. Assets may be taxed in this Devlet, whose assets are primarily due to an overhaul of capital shares of a real estate that is directly or indirectly found in the Akite State.

5. Earnings that are due to an overhaul of the remaining assets of the previous feats of this Article will be taxed only in the same Fuel State, which is the result of an overhaul of the company. However, the capital will be taxed in the other Profitable State, if the capital gains from the previous sentence above are not a year of increased earnings, economics, and disposal.

Article 14

FREE TRADE INTEREST

1. In the event that a real person with a Human Government team has obtained free vocational services or other activities, it will be taxed only in this Azit State. However, if such services or activities are performed in this other Aper State, and the following:

a) the actual business of the actual person, in the event of the other in the Turkish in the World of America If there is a fixed location that can be performed, or

b) for the actual person, the service or the service in this other in the a total of 183 days at a time, one or several times, in any 12-month period, which either ends or ends in the corresponding fiscal year to perform the activities.

comes in at the same time, in this other "ÂKit Devlette". taxable.

In this case, only the fixed place in question Income from the service or activities performed during the period in which the actual person is in the process of being able to be omitted, or when only the actual person is in this realm, is taxed in this other Profit Transfer.

2. The term "free trade activities" is a scientific, literary, artistic, educational, educational, educational, educational, educational, lawyers, lawyers, engineers, architects, accountants and accountants. activities.

Article 15

PRINTED INTEREST

1. 16, 18, 19, and 20 are the provisions of the articles of a State, a charge of service, the salary, salary, and other such proceeds will be taxed only in this Devlet unless it is performed in the other Profit Inherit. If the service is performed on the other Devlette, the proceeds from here will be taxed on this other Devlette.

2. Looking at the 1-pearl provisions, a Profit Government team has achieved the right to a service in the State of the Republic, eyer:

a) Revenue resulting in 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. if it is not done, only the first mentioned Devlette will be taxed.

3. A ship or a service that was executed in international traffic could be taxed in the Profit State, which is the result of a service being executed in international traffic, or a service that was executed on the aircraft.

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. 7, 14, and 15 were looked at by the provisions of the pearl items, an artist of the State, a theatre, cinema, radio or television artist who performed the activities of a musician or an athlete performing in the other in the Akit State. They get it, it's taxable in this other state.

2. The income of an artist or sportsman from the activities of the artist or the sport itself, if directed to a woman, is an artist or athlete who is not alone with the provisions of 7, 14, and 15. the Akit Devlette, which is performed by its activities, is taxable.

3. An artist or athlete's income from activities performed in a Kite State, a state of the visit made entirely or substantially more than the public funds of the political subdivision or of the neighborhood administration. In this event, the data will be the exception if it is not.

Article 18

RETIREES

1. In order to avoid the provisions of the 2nd article of the 19th Amendment, regular payments, with revenues from a Kite State, and so on, are taxable in this State.

2. To compensate for the harmful damages, the pensions paid by the State's Social Security system, a lifetime of regular payments, and a number of other payments or fee payments will only be taxed in this State.

Article 19

PUBLIC TASK

1. a) A) Services provided by a real person to the state, subsection or administration of the State, political subdivision, or district administration, or funds made from funds created by subsection or by administration or by the funds generated by a real match. fee, salary, and other such payments will be taxed only in this State.

b), however, when the service is performed in the Devlet Devlette, and is real When the person is a member of the state, the fee, the salary, and other similar payments will only be taxed on this other Devlette. However, this is:

i) the citizen of the other Aper State Government; or

ii) only to the state of this state in order to perform this service. It is mandatory.

2. a) Once in the State of the United States, the State Department, the political subdivision, or the local government, or the funds that have been created by the services of this state, subdivision or administration, paid for a real time in this state. will be taxed.

b) However, the real world is a member of the State of the World, and the If it is not a citizen, the other pension will be taxed only in this country's Azokit Devlette.

3. A Department of State itself, political subdivision, or a commercial activity conducted by the local government, the fee, salary and other similar payments, and the provisions of articles 15, 16 and 18 of the retired people will be applied to the system.

Article 20

IMPORTANT AND OTHER PEOPLE

1. Payments from the resources of this State to cover the costs of an Amite State, a citizen or an intern, or an intern, or an intern, or an intern, a student or an intern who is solely involved in the purpose of education, livelihood, education, or professional education. will not be taxed on this other Devlette.

2. In the same way, I am a citizen of the State of America, or a member of the Union of America, or a member of the Union of America, for a period of time or time that is not two years old, in order to be based on the basis of the issue, or to conduct scientific research, or to pursue scientific research into a member of the Union or other. services, payments made from sources in this state will be the exception that will be granted in this state.

3. The provisions of the 2nd fikra will be applied to the resulting revenue, especially not for the interests of specific people or people, as well as in the investigation undertaken by real people for the public interest.

Article 21

LANGUAGE GELS

1. Some of the revenue elements that are not mentioned in the earlier articles of the State of a Akkit Government will be taxed only in this State.

2. Excluding the income from real estate assets described in the 2 nci feats of 6 ncis, the beneficiary of the said income of a Profit State team is in commercial operation or in commercial operation with a place of office located in the other Devlet Devlette. If a fixed place in the state is found in free professional activity and the income is paid for or there is an active view of this place or fixed site, the 1st frisk provisions will not be applied to this income. In this case, the provisions of 7 nci or 14th clause shall be applied according to the event.

Article 22

PREVENT TAX VERITABLE

The double taxation will be avoided in the following:

a) in South Africa, in any country in the South African country The provisions of the South African law in order to avoid the provisions of the South African law (not to affect the general principle in this case) are under the provisions of the South African law. The Turkish tax, which they pay by income, which can be taxable, The South African tax legislation will be ashamed of the taxes they will pay. However, the total amount of South African tax to be paid at the rate of total income in total revenue will not be expected.

b) in Turkey:

i) a Turkish concourse in South Africa in accordance with the provisions of this In the event of a taxable income, Turkey will allow a valid amount of income tax to be paid in South Africa, the tax which hits the revenue of this candle. However, for taxable income in South Africa, the amount of income tax that is calculated before the crop will not be expected.

ii) A Turkey team will only follow the provisions of the terms of the Republic. When it comes to a taxable income in Africa, Turkey can also consider the revenue that is the exception when calculating the tax of the remaining income of this candle.

Article 23

SEPARATION OF SEPARATION

1. The citizens of a State Government, in the same way, are responsible for taxes, especially in the direction of the government, or the liability, especially in the direction of the government, of the country's citizens, in particular, in the case of taxation and the need for a greater amount of taxation. They will not be subjected to taxation or to the taxpayers of this country.   This provision will be applied to the non-conunuate of one or both of the States, regardless of the 1 th provisions.

2. In order to hide the provisions of the 4th section of the 10th Amendment, a State of the State's foreign policy, in the other State of the Republic of Turkey, has less lehe than those who have carried out the same activities in the other state, in the other state. It won't be up to you.

3. The first mentioned state of the State, the state of which the state, the government, or a few mutilations of the State, the government, or its wholly owned or controlled interests of the State of the State of the World, is the first to be mentioned. They will not be subject to taxes or taxes, whether they are or are not responsible for the taxes they may be or will be otherwise.

4. These provisions will not be understood as such that a Government has to apply discounts, taxes and matrah discounts to their own people, as well as in the case of the family of Azokit.

5.   The interest of a State of the Republic of Turkey, excluding the provisions of the provisions of the 7th section of Article 11, of the 7th of the 11th Article, or 6 of the 12 articles of Article 9, is the interest paid to a member of the State of the Republic of Turkey, the interest of the purpose of the purpose of the purpose of the purpose of the purpose of the State of the Republic. In the determination of the taxable earnings of this information, such payments will be able to be downloaded as if they were made to a member of the state first mentioned in the same conditions.

6. No provision in this clause is South Africa's taxation, which could be attributed to a country in South Africa, which could be attributed to a business in South Africa, not scoring a normal tax rate imposed on the company's earnings. will not block them.

The provisions of this fikra, only non-South African non-connoisseers It will apply as long as the Bank of America Tax exemption is in effect from any of the companies that are applied in the state of the carpet.

7. The provisions of this clause shall be applied to the taxes that are contained in the 2 clause of this statement.

Article 24

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 necessary for the execution of these provisions, the United States, its political subdivisions, or its neighborhood administrations, are all set up in each of the other countries. will help to address the information required for the execution of the provisions of the internal legislation on taxes. Information source is left with 1 pearl and 2 items. Any information received by the State shall be kept confidential, such as information obtained within the framework of that State's own internal legislation, and only in the first sentence of the taxes specified or by the executive or penal or the executive or penal. 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 may open such information in court proceedings or when making judicial decisions.

2. The 1st fikra provisions, a State of the Azoth in no way:

a) legislation or administrative action of the Keni or the other taking administrative measures that will not comply with their application;

b) the legislation or the normal administrative action of the Keni or the other submit unattainable information within the framework of their actions;

c) Any commercial, sanni, professional, or commercial process, or giving information about the public order of ownership

cannot be interpreted to put it under the obligation.

Article 25

BUSINESS MANAGEMENT PROCEDURE

1. A State of the State is the most likely to create or create a tax on the provisions of one of the States, or the provisions of both, for the provisions of the State, or the provisions of the State. If the authorities and the state of the State of the State in the event of the incident are in accordance with the state's authority or the 1st of the 23rd Article, it is the authority of the government of the State of the United States, which is a citizen of the state. The acquis is made during the time stipulate in the domestic legislation of the State of the United States.

2. If a satisfactory solution is not resolved, the competent authority will strive to understand the country's competent authority, in an effort to avoid a satisfactory tax, if it is not resolved to a satisfactory solution. All agreed to be implemented within the time stipulated in the domestic legislation of the State of Turkey.

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 State States can communicate with each other in order to reach an understanding of the issues outlined in the previous series of frisks. In order to reach an understanding, verbal and verbal information is deemed necessary, so it can be conducted through a panel of representatives of the authorized authorities of the State of America.

Article 26

IDPLOMAT GOVERNMENT OFFICERS AND

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 27

CURRENT LEAVE

1. Each of the countries will report to the conclusion that the work stipulate in its domestic legislation is complete before this will take effect. The following will be effective at the time of the last of these notifications.

2. The provisions of the statement:

a) In the direction of taxes that are expressed in the source, the current entry is effective for the first day of January following the date, or for the amounts paid or debunted later; and

b) From the direction of taxes, following the current date of the decision For taxation years that are the first day of January, or later,baþlayan

will be sentenced.

Article 28

CURRENT WITHDRAWAL

1. This will remain in effect indefinitely, but in all of the United States, any calendar year after a period of 5 years after the meaning of the agreement has been diplomatically revoked by diplomatic means before the 30th day of June. It will be able to terminate it by issuing a report.

2. Do Not Understand:

a) In the direction of taxes, annuification of the annuiification of the annuies for the amounts paid or charged after the end of the calendar year; and

b) The calendar year of annulment of annulment taxes. For taxation years after the end of the year

will not be convicted.

signs these HUSSEs from TEYA, Fully authorized representatives of the governments have signed the statement, and sealed their seal.

in Turkish and English languages, both text-to-be-valid On 03/03/2005, it is organized in Pretoria.

 

              Republic of Turkey South Republic of Africa

                          Name of Name

                         (Israel)