a) The storage of the same and only property, property, or trade of the business. or its use for delivery purposes;

b) Inventory of the commodity or trade belonging to the business, only for storage, contact, or delivery purposes;

c) stocks of business belonging or commercials belonging to the business, the purpose of getting started with only one person;

d) A fixed place where a fixed location is only available for purchase or collection of goods or commercials,

e) has been prepared or helped by a fixed location for the operation of a fixed location. elde

f) A fixed location of the collective activity that occurs if an all-in-one execution is performed, or the location of the half character, if performed together, one or more of the activities mentioned in the "a" to "e" for.

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 forward trader has an interest in this State for conducting an incident in a Dealer State with an ongoing trader, general commission agency, or any agency that has status on the status of a member state.

6. A company that is a member of the State of a âcketer, controls a company that is the member of the other, or if it is controlled by, or is controlled by, a company that is involved in commercialized activity in this other state. will not form an office for any other.

MADDE 6

OBTAINED FROM ASSETS

1. Income from the real estate assets found in the other Akit Devlette (including income 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 located. The term is a real estate property, real estate owned by real estate, property and forestry vehicles and animals (including honey production and ability), private law provisions, and other real estate assets. It will cover the rights of the indent rights and mines, resources and other real estate, whether it is fixed or stable; ships, vapes and planes are real estate assets. it will not be counted.

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 revenue generated from real estate assets and income from real estate assets.

MADADE. 7

TOTAL EARNINGS

1. The commercial gain of the State's government will be taxed only in this State, as it does not engage in commercialized activity in the case of the telemarkeet, in the case of the teleport, the Turkish in the country. If the United States has engaged in a commercial operation, the profits may be taxed in this other state, including only the amount that can be attributed to the current state.

2. In the event of a policy in the State of the Republic of Azite, to remain withheld by the 3rd fikra provisions, both in the Azite State, under the same or similar conditions, were the same or the same. If the total number of activities that are in similar activities, completely separate, and in a different way than the one where they have been started, the same amount of benefit will be made.

3. When determining a location, you will be allowed to download expenses for the site, including the general administration and administrative expenses, in the state where the location is located.

4. In the event that a United States has been able to determine its ability to share the total earnings per annum, a winner will not be able to win a tax on a taxable basis, unless the company has been able to determine its total earnings per share. will not prevent the application from specifying such a payout method with the mutaden application. However, the method of sharing that will be applied shall be in accordance with the principles set out in this item.

5. No gain will be attributed to the workplace by any means of goods or commercials by this location alone.

6. Regardless of the purposes of the previous fuses, the benefits that can be attributed rather than reasonable, but not a reasonable and valid reason, will be determined by the same method.

7. The provisions of this clause shall not be affected by the provisions of this clause, as the benefit includes the revenue elements that are organized separately in other articles.

ARTICLE 8

INTERNATIONAL TAILING

1. The gain from which a Skit State team will be forced to ship, ship, plane or land transmission in international traffic will be taxed only in this State.

2. The 1st phase provisions of this Article shall also be applied to an associate, a partner, or an earnings call to an international accuser.

MADDE 9

BASED CONTACT

1. a) In the management, control or capital of the Government's government, or

b) a Indirect State, or indirectly, in the case of a State of the State's foreign policy, or indirectly, a Âkit State community. The management, control or capital of the state government,

and both states, both trade and financial relations between the two buses, or imposed conditions, need to be in the search for a number of other people. But this is what we need to be in one of these people, but this is the one that's going to happen. The gain that does not show itself through the conditions is added to the benefit of that contact and 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 fix is justified, then in the case of the proceeds, the state will make the necessary corrections to the tax on the proceeds of the proposed tax. When making this correction, the other provisions of this will be considered and required by the competent authorities of the United States.

ARTICLE 10

THEMES

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, in the case of the company that made the dividend payment, in the case of Adam Devlette and the government of this state; however, the true beneficiary of the dividend, the real beneficiary of the dividend, is the tax that will be taken. will not address the following rates:

a) The actual beneficiary is a 5 percent of the gross dividend (excluding the partners), if the company is a company that holds at least 25 percent of the capital's capital from its capital, excluding those of a 5 percent of the gross dividend amount. aling="JUSTIFY "> b) 10 percent 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. Based on the legislation of the state where the company is the subject of the taxation, the revenue from other companies that receive the same treatment as the revenue from the taxation direction is the fund and the revenue that is obtained from the partnership of the yacht.

4. In accordance with Article 7, the winner of a convenience store in commercial activity in the country in which it has been taxed in accordance with the remaining part of the article, in accordance with 2/b of the remaining part of the article in the company. taxable.

5. The true beneficiary of the dividend, a Combat Government team, is found in commercial activity, or a fixed place in Slovakia, in a stable location in Slovakia, where the company who pays the dividend is a member of the company, which pays for its dividend. If it is found in professional activity and there is an active view of this office or fixed site, the provisions of the 1st and 2nd fikra will not apply. In this case, the 7 nci or 14th clause will be applied according to the event.

ARTICLE 11

FAİZ

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 interest in making interest will not, in this way, tax 10 per cent of the gross amount of the interest.

3. Looking at 2 nci fakra provisions:

a) the interest paid to the Government of Turkey and the Central Bank of the Republic of Turkey will be exempted from Slovak tax;

b) in Turkey and Any interest paid to the Government of Slovakia or to the National Bank of Slovakia will be exempted from the Turkish tax.

4. The term "interest", used in this material, is derived from all types of creditless revenue and, in particular, the bonds or bonds of public securities, whether or not to guarantee the mortgage guarantee or to contribute to the debt. statements.

5. The real beneficiary of the interest in a Kite State team is found in commercial activity with an office in the country where interest is obtained, or in a fixed place in Slovakia, in a fixed place in Slovakia, a country of interest in the interest. If it is found and if there is an active view of this office or fixed site with the payment of that interest, the 1st and 2nd fikra provisions will not be applied. In this case, the provisions of 7 nci or 14th clause shall be applied.

6. A State itself, its political subdivision, its neighborhood administration, or the interest paid by a member of this State, will be considered to be achieved in the State of the United States. However, the interest-paying person is either a member of a Kite State, or if the fact that it has a fixed place, whether it has a fixed place or a fixed place, with the debt-to-credit relationship that is causing interest to pay off in a World of Love, and interest is not on the site or the fixed place. Devlette

7, where the site or fixed location is found. 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.

NON-INFORMAL RIGHTS

1. The non-gayrimadm rights, which are paid to a member of a Âkit Devlette and in the other, may be taxed on this other Devlette.

2. However, the cost of the non-unofficial rights may be taxed according to the legislation of the State and the State of the State; however, the real beneficiary of the non-unofficial rights price is the tax on the property. It will not take up to 10 percent of the non-Gayrimaddian rights fee.

3. The term "informal rights" is used in this material, including bands used in movies and radio and television, as well as any kind of copyright, any kind of patent, any kind of patent, any kind of difference between the movies and the radio and television. It covers any payments made available to the use or use of the model, plan, secret formula, or production method, or lead or use of scientific, commercial or scientific equipment, or civil, commercial, or scientific experience.

4. The true beneficiary of the cost of an Akit State is a real beneficiary, if it is found in commercial activity, or in a fixed place in Slovakia, in the case of a Turkey-based company in the country. 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 7 nci or 14th clause shall be applied.

5. A State itself, its political subdivision, its neighborhood administration, or the amount of the non-diligent right paid for by a member of this State, will be accepted in that Akite State. However, the person who paid the non-purpose of the non-diligent right has a claim or lack of merit, or a fixed place, with the right or the heir to pay the price of an invigorated rights in the State of a Endeavor, and the non-diligent right of the State. If the price is downloaded by this location or fixed site, the value of the non-diligent right, place, or fixed location will be accepted.

6. The use of the amount of diligent rights paid in rights or information is the actual beneficiary between the payable and the actual beneficiary, or both due to the fact that there is no such relationship, due to the special relationship between the other and the actual beneficiary. 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 according to the legislation of each of the Azoys.

CAPITAL DEC ARKAZANÇLARI

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 owned by the securities, including a commercial entity owned by a Kite State team, or in a fixed place to perform free business activity in a Fuel State party, including in the ticker state. Proceeds from an overhaul of the assets may be taxed at this other State, including the benefit of this (either alone or with the entire team) or from an overhaul of the fixed site.

3. The proceeds from disposal of the securities related to the ship, the boat, the aircraft or the land transfer vasses, or the ship, homeland, aircraft or land transmission were issued in an event of the State of the Republic, the ship, the ship, the aircraft or land transmission. will only be taxed in this Devlette.

4. Earnings that are due to an overhaul of the remaining assets of the 1, 2, and 3-frictions will be taxed only in the area where the result of an overhaul is the muchas. However, the resulting capital gains will be taxed in the other Profitable State, if the capital value mentioned in the sentence preceding it is not a year of increased earnings, economics, and disposal.

MADDE 14

FREE TRADE CHAPTERS

1. The revenue that a State team has acquired through free trade activities or other activities in which it is common is that it does not have a constant place to use it continuously to perform its activities in the region of Azite, but only 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, religious, artistic, educational, educational and educational activities that are carried out in particular, as well as the doctors, lawyers, engineers, architects, workers, accountants. scope of activities.

ARTICLE 15

STALE FAILINGS

1. The provisions of articles 16, 18, 19, and 20 to remain withheld, a charge of service of a Profit Government has been obtained through a service, the salary and other such revenues are not only the first to be mentioned, unless this service is being performed in the other Devlette Devlette. will be taxed. If the service is executed in the other Devlette, the proceeds from here may be taxed in this other Devlette.

2. Looking at the 1st of the pearl provisions, a PROFIT STATE has achieved a service in the Sovereign State of the Republic of Turkey:

a) Revenue resulting in a calendar year or end of the related calendar year. If a total of 183 days is about to be lost for one or several times in any twelve month period, and

b) Payment is done by an issuer who is not the member of the other State or such an issuing name, and

c) Payment is from a place or fixed place where the business has the other Devlet If not done

will only be taxed on the first mentioned Devlette.

3. The provisions of this article prior to this, a ship, an international traffic ship, a ship, an aircraft or a land transfer in international traffic, comes from a service that is being performed, but only in this State of the State. will be taxed.

ARTICLE 16

PAYMENTS TO PRINCIPALS

A Profit has been obtained by a member of the Department of State who is a member of the Board of Directors. fee and other such payments may be taxed on this other Devlette.

MADDE 17

ARTIST AND SPORTSMEN

1. The state of theater, cinema, radio or television art, which is a member of the State of the Republic, to be looked at in the 14th and 15th article provisions, has been achieved by such activities as a musician or a sportsman in the Turkish State of the Union. income may be taxable in this other Devlette.

2. When an artist or athlete performs such activities, whether the artist or the athlete himself is directed to a woman, this comes from the provisions of the 7th, 14, and 15-terms, artist or athlete. is taxable.

3. An artist or athlete's income from activities performed in a Kite State, in the event that the state's visit to this State is supported by the public funds of the State Department, political sub-division, or the local government. tax will be the exception.

ARTICLE 18

RETIREES

1. Pensions and other similar incomes, paid for by the transition to a Âkit State team, will be taxed only in this Devlet.

2, to remain withheld to the 1st of the 19th Articles of Article. The term "Regular Payment" is a certain amount of time to pay for a lifetime or a certain amount of time, at certain times, depending on the commitment to pay for full and sufficient payment, in which money or money is measured in a measurable benefit. amount.

3. To compensate for the harmful damages, the pensions, which were paid by one of the State or its political subdivisions, and other sustained or increased payments for life, are only in this State of State. taxable.

MADDE 19

PUBLIC RETURN

1. The State, subsection or administration of the State, sub-division or administration, pension and fee-like payments, retired to a World State, political sub-section or neighbourhood administration by a real person. Only this Devlette will be taxed, including the people.

2. 15, 16 and 18 of the articles of article 15, 16 and 18 are the provisions of a State of the State, political subdivision, or financial services carried out by the local government, including the number of retired and fee-like payments and the provisions of the state. will be applied.

ARTICLE 20

FACTORS AND OTHERS

1. A member of the State of Akit and the other, in the case of a student or intern in the event of my professional or professional education, is made from sources in this other state to cover the costs of livelihood, education or professional education. payments will not be taxed on this other Devlette.

2. In the same way, I believe that a member of the State of America, a member of the Sitel State, and a member of the other or other members of the United States who are involved in scientific research for a period of time or time that does not take place in the first state of the World of America, is the result of a member or a member of the other. Revenues from the state's resources will be the exception of this policy.

3. A member of the State of Akit, or an intern, will not take part in any of the first years in the first year to win 183 days in the first year of the State, to win any of the practice interests or occupation of the state. Revenues will not be taxed in this language.

ARTICLE 21

INDIRECT VALUES

1. Any revenue element that is not specified in the earlier articles of a Âkit Government contact will be taxed only in this State.

2. Excluding the revenue from real estate assets described in the 2-nci fund of the 6 ncis of matter, a Profit Government ' s team has been able to ensure that it has been executed by an office located in the other Devlette Devlette, or the stable of this other State. if there is an effective view of the revenue or the right or barrel between the fixed site or the fixed site, the provisions of the 1st fikra will not be applied if the revenue from the free business activities that is performed by a site is found to be effective. In this case, the 7 nci or 14th clause provisions will be applied.

ARTICLE 22

PREVENTÇÝFTE

1. Double taxation in the direction of Turkey will be avoided:

a) A taxable income can be taxed in Slovakia with respect to the provisions of a Turkey, (b) excluding revenues that are covered in self-contained. In the event, Turkey will be the exception to this revenue; however, when calculating the tax on the remaining income of this winter, the exception will be able to apply a tax rate, taking into account the revenue that is being taken into account as if they were not the exception to the tax.

b) A Turkey mystery is the 13th with items 10, 11 and 12 of the State. According to the provisions of the 4th section of the article 4, Turkey will allow a tax on tax to be paid in Slovakia, which is a tax on the income of this person.

This will not address the amount of tax calculated prior to the crop, attributed to revenue that may be taxable in Slovakia.

2. Slovakia will avoid double taxation in terms of its contacts:

The Slovak Republic will tax revenue, which is taxable in Turkey, according to the provisions of the Judgment. may include the matrahna, but the tax payable in Turkey, which is calculated over the specified matrah, will allow for a total amount of tax.

ARTICLE 23

FAILURE TO DO">

1. In particular, the country's citizens, in particular the State of the United States, have either lost or increased taxes or other taxpayers ' money, especially from the public, in particular, in the case of the government, in particular, the State's State of the World. will not be subjected to a taxation or to the liability of a government.

2. The provisions of the 4th section of the 10th Amendment are intended to remain withheld, an area of the Turkish State's foreign policy, less lehe state, and less lehe in other states, according to their business, which carries out the same activities. It will not remain.

3. The governments of a State of the World, in which one or a few mutilations of the State of the World, in which the government or its fully capitalises, or are controlled, are the first to be referred to in the state of the state, the state of which is the state of the State. They will not be subject to the taxes or taxation of which they may or may not be subject to taxation, or otherwise, they will not be subject to taxation.

4. These provisions will not be understood that a Government has to apply discounts, taxes, and matrah discounts to their own party and to the Government of Azkit.

5. The 9th Amendment, excluding the provisions of the 7th of the 11th article or the provisions of 6 of the 12 articles of Article 11, is the interest paid to a member of the State of the Republic of Turkey, the interest of the non-diligent rights and other payments, which are paid by the State of the Republic of Turkey. In the determination of the taxable earnings of the community, these payments will be reduced as if they were made to a member of the State originally mentioned in the same conditions.

MADDE 24

DECISION-MAKING

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 following will must be done within the time specified in the internal legislation of the United States.

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, authorities can also dance to avoid double taxation resulting from situations that are not addressed.

4. The authorities of the United States can communicate with each other in order to reach the understanding of the issues outlined in the previous fats. 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.

ARTICLE 25

RELATED DEIDEADEÐÝÞÝMÝ

1. As long as the competent authorities of the State States do not have the information or the information required for the execution of these provisions, the authorities are required to execute the provisions of the internal legislation relating to the taxes under the scope of the legislation. They're going to put the information on my desk. The information description has not been deleted by the 1st bullet. Any information received by the State of the State shall be confidential, such as information obtained within the framework of that State's own internal legislation, and only with the tax or penalty enforcement or penalty of the taxes specified in this statement, or the law. will be given to the office or authorities (including the official authorities and administrative organizations) to address the grievances and objections of the complaints. 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. 1-pearl provisions, no Surte State:

a) Do not take administrative measures that do not comply with the legislation or administration of the Republic of America;

b), or the state of the other submit information that cannot be obtained within the framework of its legislation or normal administration;

c) Information about public order, or information that has made you public, financial, legal, colleague or commercialized business.

cannot be interpreted to put the obligation under its obligation.

MADDE 26

OFFICERS AND CONSULATE

OFFICERS

The provisions of this statement are international against the officers or consular officers of the diplomat's government. It will not affect any of the benefits of the law and the provisions of the law will not affect any of the benefits of the law.

MADDE 27

EFFECTIVE

1. This will be approved and the approval documents will be teed at the most time at the time ........................

2. The following will be effective immediately after the approval of the approval documents, and its provisions are:

a) The first day of January following the effective date of the applicable taxes, or later, paid or later, following the applicable date of taxes in the Source. For quantities (and

b) taxes,yönünden

for the first day of January following the date of which this statement is effective, or for any subsequent taxation years.

MADDE 28

WITHDRAWAL

This information will remain in effect until an annuities are annuied by a State of the Force. Each of the United States is due to issue diplomatic means by diplomatic means at least six months before the end of any calendar year after the end of a period of time before the beginning of the beginning. He can dissolve the deal. In this case, the Meaning:

a is for the amounts paid or destroyed after the end of the calendar year in which the annulment is issued; and

b) Divest taxes, annulment.

will not be sentenced for taxation years after the end of the calendar year for which they have been issued.

The full authorized reps from these HUSSEs, including those who have signed, do not understand this They signed and sealed their seals.

Turk, In Slovak and English languages, all three texts are equally valid, in the history of ....................... also edited. If there is no difference between the text, the English text will be valid.

TURKISH REPUBLIC SLOVAK REPUBLIC

ADINA