UNDERSTANDING THE REPUBLIC OF TURKEY
MEANS OF PREVENTING
PREVENTING AND ADDING
THE PROTOCOL ELIGIBLE FOR APPROVAL
Kanun # 4429
Accepted Date: 30.7.1999
MADDE 1. - The "Agreement between the Republic of Turkey and the Kuwaiti State in the State of Kuwait and the Prevention of Double Taxation on the State of Kuwait" signed in Kuwait on 6 October 1997 is appropriate to approve.
MADDE 2. - This will take effect on the release date of the Channel.
MADDE 3. - The Council of Ministers executes the provisions of this Law.
REPUBLIC OF TURKEY">
REPUBLIC OF TURKEY
Revenue and fortune by doing a comment that prevents double taxation on tax on taxes,
UNDERSTANDING THE FOLLOWING:
This will apply to the response of one or both of the Âkit States.
1. This means that no matter how much it has been taken, it comes in the name of a State or political subdivision or neighborhood government, and will apply to taxes on a wealth of wealth.
2. Total revenue, including taxes paid on a total amount of salary or fees, and taxes on a total amount of salary or fees, including taxes levied on earnings from the transfer of real estate or real estate assets. All taxes, income or income received over the elements of wealth or wealth will be considered as taxes from income and wealth.
3. Taxes applicable to the }
i) institutions tax;
ii) net of common companies to the Kuwait Scientific Arrival Foundation (KFAS). their share of other contributions collected instead of income tax, including those paid as a certain percentage of their earnings; and
(Will be mentioned as "Kuwait Tax");
b) in Turkey:
i) income tax;
ii) corporate tax; and
iii) fund share received over income tax and corporate tax;
(This will be mentioned 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 inform each other of the significant depositions made in tax regulations.
1. The term "Kuwait" refers to the State of Kuwait and, in accordance with international law, Kuwait's sovereign rights and use of Kuwait's sovereign rights and powers in accordance with international law, unless the text is otherwise predicted.
b) The term "Turkey" refers to the country's sovereignty area and territorial waters in accordance with international law, "Turkey". Jurisdiction, sovereignty, and protection for the benefit or protection of the refers to the areas of the sea where they have rights;
c) "State of a Aper" and "Diyer in Government" means Kuwait or Turkey according to the text of the text;
d) "Tax" is the 2nd term of this statement the term
e) refers to any "Kishi" term, a real person, any company and any other installation;
f) the term "February", any institution, or any other organization income of any organization that is treated as an institution in the direction of taxation;
g) The term "registered center" means "place as institutionalized" or registered according to the Turkish Commercial Code;
h) "Citizen" term:
i) Kuwait "Turkish Citizen's Law", "Turkish Citizen's Law", in the direction of any real language with the citizen of Kuwait and any provision of status based on the legislation in effect in Kuwait, including:
ii) Turkey. Any real person who has obtained Turkish citizenship and in Turkey is a real person Any provision, partner, partner, or association,
refers to any provision that is in effect, according to the terms of"
i) "A Aper of State," and "in the case of the other" In the Republic of America "terms, a" It refers to a contact that is being pushed by the party's party, and a business that has been pushed out by the member of the other Âkit Devlet;
j) " Authority:
i) in Kuwait, the Finance Minister or the authority representative;
ii) in Turkey, the Ministry of Finance or the authority Âkit
k)" Internationalized traffic ", except for the fact that only Kuwait or the ship, aircraft or land transport executionship that has been realised within Turkey's slush, is a Fuel. It refers to the construction of a ship, aircraft or land transport by the state's contact.
2. If the text does not suggest otherwise, any term that is not defined in the expression will result in the legislation of the State that is subject to the legislation.
1. For the purposes of this Business, the term "a Instrument State" is:
a) Kuwait direction:
i) a real person with a member of Kuwait and a citizen of Kuwait; and
ii) in Kuwait A company that has been installed;
b) is any part of the United Kingdom, where the house, residence, registered center, job center, or similar criteria in Turkey are subject to the taxpayer,
2. From the purposes of the 1st of the 1st line, a Âkit Government candle:
a) Government or political subdivision or neighborhood administration; and
b) any institution, authority, authority that is established in this Âkit State The time, commission, or other installs,
, will be covered.
3. 1 The state of the following will be determined by the state of this individual in the case of a fact, in the case of a real person:
a) The person who has a permanent residence is accepted by the state of the State of the State.
b) If both Develes have a permanent stay-on both state, the performance of the state will be accepted (central to vital interests) of the state, where their personal and economic relations are more closely related;
c) State of the center of the vital interests of the Eucer winter If it cannot be determined, or if the person does not have a table to remain permanently in both Sükit Devlette, the user will be accepted to the Government of Azel, where there is no longer;
d) both in each of the Azoese Devlette (s) remain in the If there is a home, or both Devlette, such a home is not in question, the government will be accepted.
4. The muchas of the Âkit State of the active management center will be accepted when both of the people in the real part of the real part of the real part of the series of fiirst provisions are part of the actual business. If the active management center cannot be determined, authorities in the countries will determine which state of the purpose of the purpose of this statement should be counted.
2. The term "workplace" is particularly scoped to:
a) the Administration place;
b) the Feb;
f) Any location, and
g) Nine months of a period of nine months of construction, construction or installation project.
3, which is a site of any other site, and
g) has been abandoned. Any previous provisions of this clause will be considered to cover the term "workplace":
a) The bus offerings will not only store property or commercial property of private, private. or its purpose for delivery;
b) The goods or commercial stocks belonging to the following are retained only for storage, private or delivery purposes;
c) Inventory of commodity or commercial stocks that belong to the business, elde
d) A fixed location of a fixed location, only for the purpose of collecting or collecting goods or trading on a fixed site,
e } is only prepared or helpful for the operation of a fixed location. elde
f) A fixed location that is intended to be performed together with the preparation or performance of the collective activity that occurs if performing together. for one or more of the activities mentioned in the e) only retention.
4. Except for a part of the 1st and 2nd fikra provisions, except for an agency that is a part of -5 Pearl-a Akitel Devlette moves to the Nam and its account, and has the authority to make a commitment to the name of that service. If it uses the authority from the mutaden, the activities of this part are described in the third storm, and through activities that are not in place of this fixed place where it is conducted through a fixed site, it is the same as this one. He was a member of the state in any way that he was able to do anything for the United States. The owner will be accepted.
5. A State of the Union government has a job in the State of the Union, only to conduct an emergency, a general commission agency, a general commission agency, or any agency that has status as a candidate for any other agency in the state of the Republic of Azite. It won't be accepted. However, in the event that the activities of such an agency are completely exclusive in any calendar year, this part will not be considered as an agent in the status of this issue.
6. A company that is a member of the State of a âcketer, a member of the Deviler Devlet, or the other, controls a company engaged in commercial activity, or if it is controlled by it (in a workplace or in other way), from these companies. will not form an office for any other.
OBTAINED FROM ASSETS
1. Income from the real estate assets found in the other Akit Devlette (including revenue from agriculture or forestry) may be taxed in this other Devlette.
2. The term "real estate" will be defined according to the legislation of the entity in which it is contained. In any case, the real estate and its products and animals, used in agriculture and forestry, have rights to real estate ownership, real estate property applicable to the provisions of private law, and livestock, the term said, and the real estate. Ships, ships, and planes will not be listed in real estate if they are fixed or stable, whether they are fixed or to be involved in the operation of the mineral quarts, resources, and other sources of the mine.
3. The 1st fikra provisions will apply 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 proceeds from real estate assets, derived from real estate entities, as well as revenue from real estate entities.
1. The commercial gain 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, Akit Devlette. If the United States is engaged in commercial activity above, the earnings of the country may be taxed in this other state, with only the amount that can be attributed to the business.
2. The 3rd fikra provisions are in commercial operation with a place of State for the State of the Republic of America, in the same place as the same place, in both Sükit Devlette and under similar conditions, the same or similar conditions under the same conditions as the other. If it is a complete separation of similar activities and a non-experience, and regardless of how much it will gain from the person who has been involved in the event, a similar amount will be attributed.
3. When determining a location, any expenses for the office will be allowed to be downloaded, including administrative and administrative expenses, or in a state where the location is located. However, the cost of compensation, fee or other similar payments made by the workplace to the main center or to use of patents or other rights in other offices are not paid for by the private services or management of the other. The fees paid by the loan, excluding the banking contact, will not be tolerated (except for the reimbursement of actual expenses).
4. No gain will be made at any cost to the site, only if it has been received by the office of goods or merchandise alone.
5. The provisions of those provisions will not be affected by the provisions of this clause, as the benefit includes elements of revenue held separately in other articles.
CARRIER, AIR, AND LAND TRANSPORT
1. In the event that a foreign trafficled from the ship, aircraft or land transmission is in international traffic, the proceeds will be taxed at the Azit State, where only the registration center is located.
2. The 1st frikra provisions will also be a match to an associate, a partner, or an agency that has been pushed into an international accuser.
1. a) The management, control, or capital of the Government's government, or
b), indirectly, or indirectly, in the management, control or capital of a Âkit State community, or indirectly, in the case of a State of the Republic of Azite State. The administration, control or capital of the state's government, and both states and financial and financial relations of the two countries are aware of the conditions under which they need to be involved in the conditions between us and the people who are involved in the development. It must have been one of the people in the community, but with these conditions, it was self-induced. the non-showing benefit is added to the earnings of that contact and it may be taxed accordingly.
2. A State of the Union can tax and tax the profits of one of their own, a member of the Union's government, in which the state's tax will be taxed at the Devlet Devlette. The state, which is mentioned in the two-to-one, is the same as the two conditions that are valid between the two countries, but the profits that are included in this country are likely to gain their own, and the State of the Republic of Turkey is also in the process of making the same. If the right to fix it, he will make the necessary corrections to the tax on the proceeds of the State of the Union, in the case of the proceeds. As you make corrections, you will observe the other provisions of this statement and will consult the competent authorities of the United States.
1. A dividend paid by a company that is the party of a State of the State may be taxed in this other Devlette.
2. However, they may be taxed at the same time that the company who made the payment is a member of the government and the legislation of this state; however, the real beneficiary of the subject matter is the tax-related dividend that will be received in this way. will not be up to 10 per cent of the amount.
3. The term "dividend", used in this material, is derived from stocks, intifas, or indent rights, mineral shares, constituent stocks, or other derived from other rights, which bear the gain or not to take credit. According to the state of the state, which is the company of the company that conducts the application, the revenue from the other company's fund and the revenue from the business of the yacht, which is treated as a result of the revenue from taxation, is the same as the proceeds from the tax-related revenue. expression.
4. The winner of a commercial activity in commercial activity with an office in the Diker Azit Devlette company, after being taxed according to the 7th Amendment, in accordance with the remaining part of the fund, in accordance with the remaining part of 2. taxable.
5. The true beneficiary of the dividend, a Combat Government team, found commercial activity in a place where the company, which pays the dividend, was found in commercial activity and was actively engaged in the search for the business, a place in which the company was a man. if it is found, the provisions of the 1st and 2nd fikra shall not be applied. In this case, the 7 nci provisions will be applied.
1. The interest paid to a member of the Instrument State and the other in the realm of the other in the Devlet State may be taxed on this other Devlette.
2. However, this interest may also be taxed according to the Minister of Atkit and the State of the State, but the real beneficiary of the subject's interest will not be 10% of the gross amount of interest in your tax interest.
3. The term "interest" used in this material is derived from all types of creditees with revenues from public securities, bonds or bonds, regardless of whether or not to guarantee the mortgage guarantee or to contribute to the debt. And the amount of revenue that is counted according to the tax legislation of the State, which is obtained by revenue, represents all revenue.
4. The true beneficiary of the interest in a Âkit Government team is found in commercial activity with the entity in which the interest is obtained, and if there is an active interest in the interest of the payment in question, the 1st and 2nd will be effective. The nci fikra provisions will not be applied. In this case, the 7 nci provisions will be applied.
5. A State itself, its political or administrative subdivision, its neighborhood administration, or the interest paid by a member of this State, will be accepted in that state. However, the interest of an interest-paying person, whether it is a policy or not, has a debt-to-credit relationship, which is due to pay off interest in a Âkit Devlette, and the interest is being taken off by this office, the interest of the interest. It will be accepted in the state where the location is located.
6. The amount of interest paid in the credit is 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 that will be determined between the beneficiary and the leper. On the other hand, the provisions of this matter will be applied to the amount of the most recent cited quantity. In this case, the additional payment will be taxed according to the legislation of each of the Azoys.
COSTS OF THE COST
1. The value of an invigorate claim paid to a member of the Aper State and the other in the Realm Realm may be taxed on this other Devlette.
2. However, the cost of monetary rights may be taxed according to the Minister's State and the State of the State, however, if the real beneficiary of the subject is the real beneficiary of the cost of the subject, the tax will be reproduced in this way. It will not take up 10 per cent of the gross amount of the cost of the gayrimaterial.
3. The term "Gayrimaterial rights" used in this material is a literary, artistic, scientific, scientific, copyright of any kind, including bands used in radio and television broadcasts with motion picture films, as well as any patent, any kind of difference between the films and the radio. The model includes any payments made by the plan, hidden formula, or production method, or any payments that are made to the right of use.
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 Kuwait, in a fixed location in Kuwait. if free professional activity is found and there is an active view of this office or fixed site with the right or the right to be paid, the provisions of the 1st and 2nd fikra shall not be applied. In this case, the provisions of the article 7 or 15 will be applied.
5. The State itself, the political or administrative subdivision, the district administration, or the amount of the non-monetary rights paid by a team of this State will be accepted in that State. However, the person who pays the price for diligent eligibility, whether it is a member of a Kite State or not, has a fixed place or a fixed place, with the obligation to pay the right to an illegitimate right in the State of the Endeavor. If the cost of this place or fixed place is being downloaded, the value of the right or fixed location will be accepted.
6. The amount of the amount of money that is paid for use, right or information, or the actual and actual beneficiary of the actual and real beneficiary between the payable or both, and the actual beneficiary of such a relationship, is the actual beneficiary of the value of the other. the provisions of this clause will only be applied to the most recently mentioned quantity, as the amount of time it is to be determined in the search. In this case, the additional payment will be taxed to the legislation of each of the Azoys.
1. Earnings per share of the real estate entities, which are included in the other in the event of a State of Azite, are taxable in this other State.
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 an overhaul of the assets may be taxed at this other State, including the benefit of this location (either with or with all contact), or from an overhaul of the fixed site.
3. The proceeds from overhauling securities related to the ship, aircraft or land transmission vasses, aircraft or land transmission vasses, which were pushed out in international traffic, only said that the registration center for this week's registration will be taxed in the Akili Devlette.
4. 1, 2, and 3% gain from the disposal of the remaining entities, will be taxed only in the Fuel State, where the muchas are the muchas of the person.
1. A wealth of real estate assets mentioned in article 6 of a Âkit Government clause can be taxed in this other Devlette.
2. Securities of a fixed site, including the active part of a Akitel State team, including the active part of a property owned by the Akkit Devlette, or in the case of the State of the Akkit, the Akkit Devlette in a fixed place. A wealth of assets can be taxed on this other Devlette.
3. A wealth of securities related to the operation of international traffic, aircraft and land transmission, and the operation of the ship, aircraft and land transmission were not only in the area where the centre of concern was found, said the ship's company. will be taxed.
4. All elements of fortune belonging to a Âkit State team will only be taxed in this Devlet.
1. The income of a Turkish State team in the event of free trade activities or other activities in which it has failed, is that it does not have a fixed place to use in order to perform its activities in the first place, but only if it does not have a fixed place. will be taxed in this State. If the other person has such a fixed place, only the revenue that can be attributed to that fixed site can be taxed on this other Devlette.
2. The term "free trade activities" is a scientific, literary, artistic, educational, educational, educational, educational, educational, lawyers, lawyers, engineers, architects, accountants and accountants. scope of activities.
1. 17, 19, 20, and 21 are the provisions of a State of the State team to remain withheld, while the salary, salary and other similar payments are not performed in this service, but only in the first mentioned State of the State. will be taxed. If the service is executed in the other Devlette, the proceeds from here can be taxed on this other Devlette.
2. Looking at the 1st of the pearl provisions, the revenue that a PROFIT GOVERNMENT has achieved in the other Âkit Devlette with a service indirect,eðer
a) Revenue resulting in one or more of the following calendar year (s) in this language a total of 183 days at a time, and
b) Payment is due to an imposition of this member who is not a member of the state or such an entity, and
c) Payment has been owned by the issuer of the issuer If not from a place or place of fixed place, only the first mentioned Devlette will be taxed.
3. The revenue generated by the previous provisions of this Article may be taxed in the Akit Devlette, where a ship, aircraft or land transmission is executed in international traffic, and the revenue center is located at the site of the registered centre.
PAYMENTS TO PRINCIPALS
This is the amount of compensation and similar payments made by a member of the State team to be a member of the board of directors of a company. It can be taxed in the state.
ARTIST AND ATHLETES
1. The theatre, cinema, radio or television art, which is a member of the State of the Union, has been performed by the provisions of the 15 and 16 articles, and is performed by a musician or a sport, in such a nature of the activities of the Turkish. income, which may be taxable.
2. If an artist or athlete performs such activities, whether the artist or the athlete himself is directed to a woman, this comes with the provisions of 7, 15, and 16 of the articles of athlete, artificist, or sportsman. is taxable.
3. In support of the activities of the artist or the athletes they perform in a Âkit Devlette, this Devlette visit is supported by the public funds of the State Department, the political subdivision, or the local government. , the 1st and 2nd fikra provisions will not be applied.
1. Payments similar to the retired people paid for by the passage of a US State team to remain withheld by the provisions of the 1 nci fund of Article 20 may be taxed only in this State. This provision will also apply to a lifetime of revenue, which is sold to a Revenue State team.
2. To compensate for the harmful damages, the pensions or payments of those who are paid by the State or a political subdivision of a government or its political subdivision will be taxed only in this State.
1. In a case of public service to the State, political subdivision or neighbourhood administration, it is made from the political subdivision or the local government or the funds that have been generated by the government. payments will only be taxed in this Devlet, including the retireates.
2. The payment of 16, 17 and 19 articles of articles 16, 17 and 19 will be applied to the payments and pensions of a State of the State itself, the political subdivision, or the commercial activities carried out by the district administration.
TEACHERS AND OTHERS
1. Payments from the resources of this other State to be able to become a citizen of the State of a âite and to ensure the livelihood, experience, or occupation of a student or an intern in the cause of death in the other, in the case of the State of the World, or the purpose of his or her profession. will not be taxed on this other Devlette.
2. In the same way, for a period of time or time that is not two years behind in the State of a Kite State, a member of the country or the member of the other state, in particular to pay for the duration or the scientific investigation of the time. sources, this will be the exception of the data in this state.
3. A student or intern who is a citizen of a State of the State will not be able to take part in a period of 183 in a calendar year or time of services to win applications for application or occupation of the country in which a member of the State of the World is concerned. Revenues will not be taxed in this state.
Where a Sense of State does not exist in any of the preceding items of this section non-specified revenue elements will only be taxed in this Devlet.
PUBLIC AND CORPORATE BRIDES
a) the government, political subdivision, or government of the Diaper in the Diaper to the local government;
b) (a) a complete State-owned administration, Central Bank, institution, foundation, lift fund, or agency, or other financial institution,
c) DiGite Devlette in effect installed according to the law, in the whole of the current capital (a) or (b) in their a company owned by or
d) Main central destination in the country, in the case of the entire capital, with the governments of this State or other states
1. Contrary to this agreement, the current taxation laws in the States shall continue to be enforced.
2. Double taxation will be avoided by the following provisions.
a) Kuwait direction:
A Kuwaiti mukimi, when the provisions of this statement obtain a taxable income in Turkey and in Kuwait When it has a wealth of wealth, Kuwait will allow an amount of tax that is paid by tax, which hits the revenue or fortune of this trust, over income or fortune in Turkey.
However, the subject of the subject is the subject of the For income or fortune, which can be taxed in Turkey, before the Mahsuptan is in Kuwait. will not increase the amount of tax received over either the calculated revenue or wealth.
b) In the direction of Turkey:
A Turkey team will have a taxable income in Kuwait and in Turkey under the provisions of this Judgment. Turkish tax legislation provisions, which hit the income or fortune of foreign taxes, are subject to income or wealth in Kuwait, or a tax on income or wealth, in order to avoid the provisions of Turkish tax legislation, Turkey said, or a tax on its wealth. will allow the amount of the amount.
The amount of tax, which is attributed to income or fortune in Kuwait, which may be taxable in Kuwait or attributed to the fortune, will not take place over the income or fortune that is calculated in Turkey.
3. Under the laws of a State of the State, if taxes under this information are exception or reduced for a period of time, the required or reduced taxes will be deemed to be paid for by the purposes of the previous fund's purposes.
1. A State of the State's citizens, the country's citizens, said that the State of the State would either tax or pay any taxes or other taxpayers ' money, whether they were able to stay in or out of the same law that they were concerned about. They will not be subject to liability.
2. In an area of the State's foreign policy, the country will not be involved in a taxation of less lehe, according to the local government, which operates the same activities as the state's state.
3. Any provision in this material will not be understood as if a Âkit State has to apply discounts, taxes, and matrah discounts to their own party or familial states, as well as to the Service.
4. Any provision in this clause shall not affect the right to impose an exemption or a discount on the citizen 's own connoiseance, the citizen' s own mutite. This fikra will not apply to actual people owned by the entire capital or any part of the company.Âkit
1. The competent authorities of the State States are required for the execution of the provisions of the internal legislation relating to the taxes under which the provisions are not in compliance with the information or means necessary for the execution of the provisions of this Statement. They're going to put the information on my desk. Any information received by the State shall be confidential, such as information obtained within the framework of that State's own internal legislation, and only with the arbitration or tamper of the taxes specified in this Meaning, or by the executive or penal or such. will be granted to the office or authorities (including the official authorities and administrative organizations) to look at the concerns and objections of the issues. 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 or public decisions.
2. The 1st fikra provisions are not a Sovereign State:
a) or any administrative measures that do not comply with the legislation or administrative enforcement of the State of the Republic;
b), or the other present information that cannot be obtained within the framework of its legislation or normal operations, or
c) information that makes public information or the public order that makes it public, making it possible to take any form of business, civil, or professional. exporting
the obligation under obligation cannot be interpreted.
1. A State of the State is the most enviable in the domestic legislation of the States, when one or both of the states have failed to create or create an unfavorable taxation of the provisions of the Union, a company that does not comply with the provisions of the State. If the authorities and the state of the State in the case of the incident are in accordance with the state's authority or the 1st of the 25th Amendment, the government may supply the government to the authority of the State.
2. If he sees the right of objection and cannot find a satisfactory solution to his own, he is committed to resolving the tax on such a non-compliance, in order to resolve the situation in accordance with the decision of the government.
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 contact each other to avoid double taxation resulting from situations that are not addressed.
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. To reach a point of understanding, this vision can be executed by a Commission channel that is one of the representatives of the authorized authorities.
OPTIONS AND CONSULAR OFFICERS
The provisions of this statement will not affect the financial details of the diplomats and consular officers who benefit from the provisions of the general rule of law and the provisions of special understanding.
1. The competent authorities of the Aşit States will arrive to understand the regulations regarding the implementation of the enforcement and exemptions specified in the preceding items.
2. This will not affect the right to benefit from an exemption and discounts on tax and yacht regulations, which are provided in accordance with the domestic legislation, regulations, and administrative practices of the Republic of America.
1. Each of the countries will report to the completion of the necessary steps to make this effective. This will be effective at the time the last of these notifications will be available.
2. Understand both Azit Devlette:
a) For taxes on the 1st day of January or later than the signing of the statement,
b) The year of January, the year of signing of the
shall be sentenced for taxes on the source over the interest and expiry of the dividend, interest, and non-payment of the due date shall be subject to us.
DURATION AND CURRENT LEAVE
This will remain in effect for a period of five years. It will remain in effect for the same duration or durations until it is dissolved by one of the first or later periods at the end of the first or subsequent periods, until it is annulled by a whistlebessor.
In this case, Do not understand, both in the Transfer:
a) for taxes on the first day of January, or any taxation period that may be followed by a subsequent taxation period of January;
b) The first following January is the first of the year following the date of the Fesih report.
shall not be sentenced for taxes on the source over the cost, interest, and non-diligent right of the right.
This is the full authorized reps of the two State (s). They signed the deal and gave up their seals.
Both text in the Turkish, Arab and British languages, to be equally valid, on the day of the fifth of October of 1997, Hjri 1418 of Cemadilahir Organized in Kuwait.
No differences in text In the case, the text in English will be valid.
REPUBLIC OF TURKEY
Işn Çelebi Nasser A. Al-Roudan State Minister Başaşaşi Assistant and Finance Minister
The Republic of Turkey, Kuwait State for the sixth day of October 1997, is 1418 In Kuwait, the community has a double tax on income and wealth in Kuwait. They understand that during the signing of the Prevention of Taxation, provisions of the above are an unallocated part of the State.
1. 7 nci:
Use or use information on the use or use of scientific, commercial or scientific equipment for the use of, or use of, the 1st form of this Article 1. Any price paid will be considered as the basis for the implementation of the 7 nci provisions.
2. 10, 11, and 12 as a matter of matter:
10, 11, and 12 items related to the terms of the "true beneficiary", a third country's interest in Turkey or Kuwait, for the cost of interest and purpose of the purpose of the purpose of interest and purpose. It will be construed to take advantage of the benefits of the deal, but it does not apply to the members of the United States at any time.
3. 20 nci:
A real person, Kuwait Airlines, or ships owned by the State, and payments made by Turkish institutions or ships that are involved, provisions related to the public service. It will be covered under article 20.
4. As for Article 23:
(d), the term "main center" will refer to the effective management center, and the exemption will be applied to the ratio of Kuwait to the capital of the institutions mentioned in this section.
THESE SERVICES WERE the full authorized reps of the two State. They signed and sealed the Protocol.
Both text in Turkish, Arab, and English languages, including the same level of the following year, October 1997. For the sixth day, Hicri 1418 was in Kuwait on the day of the month of the month. edited.
Text in English will be valid.
BEHALF OF THE TURKISH REPUBLIC OF KUWAIT
Ihead Çelebi Nasser A. Al-Roudan Minister of State, Secretary of State and Finance