Read the untranslated law here: https://www.tbmm.gov.tr/kanunlar/k4428.html
Law No. 4428:30.7.1999 Article 1. – 2 April 1997, signed in Ankara on "Turkey Republic of Slovak Republic Comes From taxes on double taxation and Preventing Tax Trafficking Agreement" to be approved.
Article 2. – This law enters into force the date of promulgation. Article 3. – This law the provisions of the Council of Ministers.
With the REPUBLIC of TURKEY, the SLOVAK REPUBLIC COMES FROM TAXES on DOUBLE TAXATION AVOIDANCE and TAX TREATY to STOP TRAFFICKING of the REPUBLIC of TURKEY and the SLOVAK REPUBLIC Income tax to prevent double taxation and taxes obtained through trafficking in the FOLLOWING WAY the request make a deal AGREED: article 1 PERSONS COVERED this agreement Âkit States people who are residents of one or both of the apply.
Article 2 the AFORE MENTIONED DATES, TAXES 1. This agreement, regardless of how it is taken, a Âkit State or political subdivisions or local authorities, on behalf of the income obtained through taxes will be applied.
2. Securities gains arising from the transfer of assets or real estate taxes are applied to the total amount of wages or salary with several attempted through taxes paid and capital increase in value including taxes applied to total revenue or revenue all taxes, income obtained through elements taken from the taxes will be considered.
3. The agreement will be applied to the currently applicable taxes in particular: a) Turkey: I) the income tax;
II) corporate tax; and iii) income tax and corporate tax share of funds obtained through; (From now on referred to as "Turkish tax");
b) in Slovakia: I) the income tax from natural persons; and ii) income tax from legal persons;
(From now on referred to as "Slovak tax").
4. This agreement will at the same time, after the date of signature of the agreement in addition to or instead of their existing tax and received the same quality of existing taxes or significantly similar to them will also be applied to taxes. Âkit States ' competent authorities, related tax legislation will notify each other of important changes in.
Article 3 GENERAL DEFINITIONS 1. In terms of the purposes of this agreement, unless the text otherwise predict: a) I) "Turkey" refers to Turkey as well as its sovereignty and territorial waters in accordance with international law, the search for the operation and preservation of natural resources for purposes of jurisdiction or sovereignty rights refers to the sea areas;
II) "Slovakia" refers to Slovak Republic and geographically, is used, in accordance with the rules of international law, sovereign rights or jurisdiction over the Slovak Republic use refers to the land of the country; b) "Âkit" and "other State Âkit State" terms, to the requirements of the text means that the Turkey or Slovakia;
c the term "tax"), in article 2 of this agreement means that any tax grasped;
d the term "person" is a real person), a company and any other body of persons;
e) "Company" refers to any institution or as treated in terms of taxation means that any organization;
the term "Registered Centre" Turkish f) trade law or according to the Slovak trade law refers to the legal registration of the main central;
g) the term "citizen"; I have A Âkit State citizenship) are there any real people;
According to the legislation in force in the State on a Âkit II) status the person, partnership or Association of any winning hükmî arenas;
h.) "and" other "Attempted A Âkit State Âkit State Initiative" terms respectively, a resident of the State-run enterprises and other Âkit Âkit means a State resident-run enterprises;
n.) "competent authority" refers to the Minister of finance, in Turkey or I) authorized representative; and Minister of finance in Slovakia or ii) authorized representative of Expression;
j the term "international traffic"), only within the limits of the Turkey or Slovakia, the ship, aircraft or land transport carried out by means of a Âkit State, excluding attempted by ship, boat, aircraft or land transport means refers to the transport of that have been made.
2. the implementation of the agreement in terms of a Âkit State; text is not defined in the agreement, unless you anticipate otherwise any term, subject to this agreement, which constitutes the tax stipulated in the legislation of the State in which the meaning.
Article 4 RESIDENT 1. For the purposes of this agreement, the term "resident of a Âkit State", in accordance with the legislation of the State House, residence, place of management or any similar structure in the Center, registered in any other crime-means people who sweat due to taxpayer.
2. the provisions of paragraph 1 and therefore a real person is resident in the State on both Âkit, that person's status will be determined in the following manner. a) this person, only permanent residents of the State where a "domicile, which can as will be accepted. If this person can remain permanently at both State if you have a home, that person, personal and economic relations will be considered a resident of the State were closer (Center of vital interests); b) If the person's vital interests cannot be determined, or the center of both the State and the State can remain as a permanent residence or, this person only where the State House acquired menstruation to remain a resident will be accepted;
c) If the person has acquired menstruation to remain at both State House or a House that is not in question, both in the State, that person shall be deemed a resident of the State, it is only the citizens;
d) if the person is a citizen of both the State and the State also is not a citizen of either or both, Âkit States competent authorities by mutual agreement to solve the problem.
3. the provisions of paragraph 1 a person other than a natural person, hence both Âkit and resident of the State, this person, only registered users will be considered a resident of the State headquarters of the. Article 5 ESTABLISHMENT 1. For the purposes of this agreement, the term "workplace", an enterprise work is being carried out, in whole or in part, means a fixed place for work.
2. the term "Workplace" in particular gets covered.
f) mining, oil or gas well, a quarry or any other place where natural resources, and a Twelve Month period g) an ongoing construction site, construction, installation or Assembly project.
3. the provisions of This article is connected with the earlier accepted the term "establishment" shall be deemed not covered by the following points;
a) facilities, Attempted only goods or commercial goods belonging to the enterprise storage, display or delivery purposes;
b) stocks of goods or commercial goods belonging to the Enterprise, only for the purpose of storage, display or delivery kept getting;
c) stocks of goods or commercial goods belonging to the Enterprise solely for the purpose of processing by another enterprise, kept getting;
d only a fixed place, for Work) to commit to purchase goods or commercial goods or information gathering purposes, kept getting;
for a fixed place for undertaking Work e) can only be preliminary or auxiliary character, for the purpose of conducting any other business kept getting;
f) exercised together resulting in collective activity preparatory or auxiliary character provided that, a fixed place for work, only the "a" to "e" in a combination of one or more of the activities mentioned Executive kept getting to;
4. the provisions of paragraphs 1 and 2 of a person connected with accepted-5 paragraph will apply except for an independent software agents-Âkit moves and a State enterprise on behalf of nam and account agreements that attempt is authorized to use this authority ordinarily; This person is mentioned and referred to paragraph 3rd paragraph activities according to the provisions of a fixed location is executed through this fixed place of business where the nature is not limited to, activities that do not make this attempt, this attempted of this person in the State to have a workplace activity of all kinds will be accepted. 5. An undertaking, only a Âkit State jobs to their business as a broker, General Commission agent or any other agent of independent status to play through in this State has accepted a workplace.
6. a company with A State resident of Âkit, a resident of the State or other Âkit that controls a company operating in the other State commercial (through a permanent establishment or otherwise), or is controlled by, any one of these companies will create an Office to the other. Article 6 INCOME FROM REAL ESTATE ENTITIES
1. a resident of the other State A Âkit Âkit revenues from real estate assets located in the State (including income from agriculture or ormancılıktan), that other State, be taxed. 2. the term "real estate assets", according to the legislation of the State of the entity in question is located, Âkit will be defined. In any event, the term müteferri entity real estate assets of each, the tools used in forestry and Agriculture and animals (including production and fish farming), to be applied to the provisions of private law rights to real estate ownership, usufruct rights, real estate and other resources of mines and natural resources operation or business as fixed or variable payments arising in Exchange for the rights to cover; ships, boats and aircraft real estate asset will not be counted.
3. the provisions of paragraph 1, arising from the use, rental real estate entity directly or other statement of income earned from the use in any way.
4. the provisions of paragraphs 1 and 3rd at the same time, the income of an enterprise real estate assets with real estate assets used in self-employment activities Executive will also be applied to income from.
Article 7 COMMERCIAL EARNINGS 1. A Âkit Government attempted to question other commercial gain, of attempted Âkit a workplace in the State unless the trade activity through, only this would be taxed in the State. If found operating the above mentioned way attempted commercial gain on the enterprise, only to be limited to the amount attributable to such other State Office to be taxed.
2. without prejudice to the provisions of 3rd paragraph, attempted a Âkit State Âkit State through a permanent establishment situated in the other commercial activity is found this to work, both Âkit in the State, if the conditions under the same or similar establishment, located in the same or similar activities, if it was a completely separate and independent enterprises and businesses completely independent attempted create what is to gain the qualification had won, , the same amount of gain atfedilecektir. 3. in determining the earnings of a permanent establishment, where the establishment is located in the State or elsewhere, General Administration and management expenses, including expenses for download will be let of the establishment.
4. A Âkit State, can be attributed to a permanent establishment profits, various units of the total winnings attempted to be shared determination on the basis of habitual, nothing can be predicted, 2nd paragraph in this Âkit State, sharing such a taxable gain ordinarily applies to determine the method of obstacle. However, the share to be applied to the method will be determined in this article the results will adhere to the principles. 5. the establishment of the Office by taking goods or commercial goods only on behalf of attempted around any gain atfedilmeyecek.
6. for the purposes of the preceding paragraph That, in contrast to the gains attributable to the workplace, reasonable and unless a valid reason will be determined the same way each year.
7. Gain, held separately in other articles of this agreement income contains elements of, the provisions of that article won't be affected provision of this article.
Article 8 INTERNATIONAL TRANSPORT 1. A Âkit attempt of international traffic in the State ship, ferry, aircraft or land transport from a means of gain would be taxed in this State which is only. 2. the provisions of paragraph 1 of the present article at the same time, depending on the business or a partnership, an international agency affiliates operated thus obtained will be used for profit.
Article 9 DEPENDENT UNDERTAKINGS 1. Âkit a) a State initiative, either directly or indirectly, the management, control or attempt other Âkit State capital joined to, or b) the same persons, either directly or indirectly attempted a Âkit State Âkit State enterprises of management, control and other, or capital, and either way, the two attempted to impose trade and financial relationships between or among the conditions the formation of independent undertakings when required conditions different , this should be one of attempted, but these conditions and therefore does not present himself, he would be added to the earnings and accordingly taxable enterprise. 2. A Âkit State so on their own initiative, to the earnings of one of Âkit Âkit State vergilendirildiği State enterprises of such other earnings include vergiley. The first mentioned State, the conditions applied between two undertakings between two independent undertakings if the circumstances were the same in this way will the earnings gains are included in the claim on their own initiative and other Âkit States will be if it comes to a point of correction, other Âkit State such gains obtained through tax-related will make the necessary correction. Any other provision of this agreement, when this correction eye will be kept and, when necessary, in front of the Âkit States competent authorities danışacaklardır to each other. Article 10 DIVIDENDS 1. A company with a State resident of Âkit by other Âkit a resident of the State, that other State taxable dividends paid.
2. However, such dividends are, at the same time, the company's dividend payout is resident according to the legislation of this State Âkit State and taxed; However, the real beneficiaries who obtain dividends, dividends, tax in this way shall not exceed the following rates: a) the real beneficiary, dividends, capital of the paying company directly at least 25 percent of a holding company (partnership) the gross amount of the dividends, 5 percent;
b) in all other cases, the gross amount of the dividends is 10 percent.
3. the term "dividends" is used in this article, the redeemed promissory notes or stocks, usufruct rights, founder shares will not profit from or other rights to participate in the nature of income is a company engaged in the distribution of resident with the State according to legislation, taxation income from stocks in terms of seeing the same treatment other company with revenues generated from the right mutual fund and investment trust refers to the proceeds obtained from. 4. Other Âkit through a permanent establishment situated in the State commercial company gain a Âkit operating in the State of establishment of Âkit after tax 7 according to the article in the State, the remaining part of this article through 2/b of the California Penal Code as appropriate to be taxed.
5. A resident of the State is the real beneficiary of dividends Âkit, temettüyü is located in the State of the other company's resident who paid Âkit a business or commercial activity through a resident of Turkey, Slovakia through a fixed place is situated in self-employment activities, and such dividends achieved e event with this establishment or fixed depends on if an active between is written in 1st and 2nd, the provisions will not apply. In this case, according to the provisions of article 7 or 14 will apply.
Article 11 INTEREST 1. A Âkit is a resident of the other State, and paid interest, Âkit State that other State, be taxed.
2. However, this interest, obtained according to the legislation of the State Âkit State and taxed; However, the real beneficiary is the person who obtained the interest interest, tax in this way, interest shall not exceed 10 per cent of the gross amount.
3. irrespective of the provisions of paragraph 2: a) born in Slovakia and the National Bank of the Republic of Turkey or Turkey Government paid interest will be exempt from the Slovak tax;
b) born in Turkey and Slovakia Slovakia's National Bank paid interest Turkish Government or tax will be exempted from.
4. the term "interest" is used in this article, whether linked to or guarantee the mortgage borrower you know you recognize the right to participate in the earnings, suitable for all kinds of proceeds arising from receivable and in particular, public securities with proceeds from bonds or bonds.
the interest is a resident of State a Âkit real beneficiary interest obtained through a permanent establishment situated in the other Âkit State commercial activities if the property is not found, or a resident of Turkey, Slovakia through a fixed place is situated in self-employment activities and will take interest in question has been paid with this establishment or fixed depends on if an active between is written in 1st and 2nd, the provisions will not apply. In this case, according to the provisions of article 7 or 14 will apply. 6. A State itself, a political subdivision, local authority or a resident of this State by Âkit interest paid will be considered that is obtained in the State. However, a resident of the State where the interest payer, whether or not a Âkit a Âkit debt interest payment in the State will take in connection with the relationship why a business, or a fixed-place and is installed by this establishment or fixed place of interest, the interest in question, where the State of the place where the establishment or fixed will be considered is obtained. 7. the amount of interest paid Will, with beneficiaries, or between a payer and both with another person because of the relationship existing between private, in the absence of such a relationship between the payer and the beneficiary exceeds the amount be determined, the provisions of this article shall apply only to the most recent mentioned amount. In this case, and any other provision of this agreement in an extra payment, taking into account the State of the legislation will be taxed according to each Âkit. GAYRİMADDÎ RIGHTS article 12 FEES 1. A Âkit is a resident of the other State, and Âkit gayrimaddî rights fees paid to the State, that other State, be taxed.
2. However, such gayrimaddî rights fees were obtained according to the legislation of the State Âkit State and also to be taxed; However, the person who obtained the rights fee gayrimaddî gayrimaddî is the real beneficiary of deserved it, in this way, you must pay for the full amount of the tax to be gayrimaddî rights gayrisafî shall not exceed 10 percent. 3. In this article the term "gayrimaddî rights fees" used films and radio and television broadcasts including bandwidth used in literary, artistic or scientific, suitable for all kinds of kinds of copyright, patent, the distinguishable, pattern or model, plan, secret formula or method of manufacture or industrial, commercial or scientific equipment, or industrial, commercial or scientific experience in the use of knowledge based on or use any payment made in return for the right to security. 4. the cost of A Âkit State gayrimaddî rights of residents of the real beneficiaries, the price in question was obtained through a permanent establishment situated in the other Âkit State commercial activities if the property is not found, or a resident of Turkey, Slovakia through a fixed place is situated in self-employment activities, and paid the price in question with the establishment of the rights or assets or fixed depends on if an active between is written in 1st and 2nd, the provisions will not apply. In this case, according to the provisions of article 7 or 14 will apply. 5. A State itself, a political subdivision, local authority or a resident of this State gayrimaddî rights paid by the cost of, it will be considered Âkit State is obtained. However, payment of the payer, deserve a gayrimaddî Âkit a Âkit, whether or not a resident of the State in the State, causes the right or pay the right gayrimaddî entity has a connection with a business, or is hard and that's the price right office or gayrimaddî fixed sights is installed by the gayrimaddî the cost of rights, including the establishment or fixed place in the State will be considered is obtained. 6. use, rights or amount of paid gayrimaddî the cost of rights information, with a payer and beneficiary, or between both with another person because of the relationship existing between private, in the absence of such a relationship between the payer and the beneficiary exceeds the amount of the actual process, the provisions of this article shall apply only to the most recent mentioned amount. In this case, and any other provision of this agreement in an extra payment, taking into account the State of the legislation will be taxed according to each Âkit. Article 13 CAPITAL GAINS FROM the INCREASE in VALUE 1. A Âkit located in the State, other State resident Âkit and 6 from the disposal of real estate asset referred to in paragraph provided that other State taxable gains.
2. A Âkit other Âkit of the State-owned State enterprises establishment of commercial presence, including a resident of State a securities, entities or Âkit other Âkit to perform self-employment activity uses the State fixed the securities belong gains from the disposal of assets, the establishment (alone or with the whole enterprise) or fixed gain arising from the disposal of the place, including this other State, be taxed. 3. when A vessel operated by international traffic State resident Âkit, vapur, aircraft or land transport vehicles, aircraft or ships in question or of land by means of the operation of the transport-related securities gains from the disposal of assets, only vergilendirilebilecektir in this State.
4. paragraphs 1, 2 and 3rd outside of specified in the gains from the disposal of assets, is the only hand out resident would be taxed in the State Âkit. However, other Âkit resulting in the State and an increase in capital value mentioned in the previous sentence gains, acquisitions and disposal does not exceed one year, the time between other Âkit State vergilendirilebilecektir. Article 14 the SELF-EMPLOYMENT ACTIVITIES 1. A resident of State a Âkit self-employment activities or other activities of an independent nature, and hence revenues, this person to perform continuously activities of other Âkit State can use a hard place unless you have, only in this State vergilendirilebilecektir. If the person is such a hard place comes hard to the floor in question only attributable to these other taxes in the State.
2. the term "self-employed activities", especially independent scientific, literary, artistic, executed as educational or tutorial activities, as well as doctors, lawyers, engineers, architects, dentists and accountants, independent of the scope of their activities. Article 15 DEPENDENT ACTIVITIES 1. 16, 18, 19 and 20, without prejudice to the provisions of article Âkit, a resident of the State of a service thus acquired, salary and other similar income, this means other services unless Âkit State, only the first-mentioned State, vergilendirilebilecektir. Service means other State, be taxed in the State in this other relevant income obtained from here.
2. irrespective of the provisions of paragraph 1, a resident of the other State a Âkit Âkit a service therefore was the State income, if: a the person who obtained Income, other State-related) calendar year beginning in any twelve-month period ended or one or a few at a time does not exceed a total of 183 days as far as I'm concerned, and to other non-residents of State b) payment, an employer is made on behalf of your employer, or by the , and c) payment, the employer's establishment or other State owned fixed sights made from only the first-mentioned State, vergilendirilebilecektir.
3. the provisions of this article, regardless of the previous State-run international traffic on a Âkit teşebbüsünce, a ship, aircraft or land transport vehicles means a revenue due a service, only in this State vergilendirilebilecektir. Article 16 WE'RE SHUTTING DOWN a resident of the State, A Âkit other PAYMENTS MADE to the Âkit member of the Board of Directors of a company which is a resident of the State due to the acquired pay and other similar payments, that other State, be taxed.
Article 17 ARTISTS and ATHLETES 1. regardless of the provisions of article 14 and 15, is a resident of a Âkit State Theatre, film, radio or television artist, or a musician, an athlete has other personal activities of this nature of the Executive Government Âkit thus, that other State taxable income.
2. has performed an artist or athlete comes from the activities of this nature, not the artist or sportsman himself is headed to another, this is 7, 14 and 15 of the provisions of articles accepted, depending on the artist or the athlete has been taxed in the State in the activities of Executive Âkit.
3. An artist or athlete exercised his activity in the State a Âkit income, this made the State visit is completely other local Government, political section of Âkit or the public funds from taxes in this State if supported, will be no exception.
Article 18 PENSIONS 1. 1st paragraph of article 19, without prejudice to the provisions on the work of a Âkit State resident of past pensions paid and other similar income, only vergilendirilebilecektir in this State.
2. the term "Regular payment" money or money in Exchange for measurable benefits, with full and adequate payment depending on the lifetime commitment is not in or can be determined for some time, certain or at certain times, covers a certain amount which will be paid on a regular basis.
3. personal damages Incurred to compensate, a Âkit State or one of its political section provided lifetime pensions paid by and other continuous with or incidental income payments will only be taxed in this State.
Article 19 PUBLIC SERVICE 1. See the subsection, or a Âkit State, local political administration is a public service and therefore a real person by services in return, this State, section, or any other similar salary made by the Administration, fees and payments, including pensions, only vergilendirilebilecektir in this State.
2. A Âkit State itself, political subdivision or local authority in Exchange for commercial activities conducted by linked services provided with salary, wages and other similar payments pensions 15, 16 and 18 shall apply to the provisions of the article. Article 20 TEACHERS and STUDENTS 1. A Âkit State Âkit State citizen and other vocational training only for the purpose of learning or a student or intern found livelihoods, education or vocational training in order to meet the costs of these other payments from sources other than the State, that other State will not tax it.
2. Likewise, a Âkit State Âkit State citizen and the other not exceeding two years, or periods of teaching or scientific research in order to make a teacher or instructor, teaching or research, in Exchange for these other revenues from sources other than the State, this will be no exception from other State taxes.
3. a student or intern, citizens of the State, A Âkit, other Âkit studied in the State or profession-related applications to win State first year habits in 183 day period or periods not to exceed the service was due to revenues, not tax these other State.
Article 21 OTHER INCOME 1. A resident of State a Âkit, no matter where he is, this agreement comes elements not specified in previous articles, only vergilendirilebilecektir in this State.
2. in paragraph 2 of article 6 of the defined real estate asset comes from a resident of State a, excluding Âkit, carried out through a permanent establishment situated in the other Âkit State commercial activities or other State has exercised through a fixed place located on self-employment income obtained from the activities, that give rise to rights or establishment or fixed place with revenue being found to be an effective bond between , will not apply the provisions of paragraph 1. In this case, according to the event, shall apply the provisions of article 7 or 14. PREVENTION of DOUBLE TAXATION article 22 1. Turkey in terms of double taxation will be avoided in the following manner of resident: a) is a resident of Turkey, (b) they come covered in this Contract, excluding vergilendirilebilen in Slovakia according to the provisions of an income tax on this income, when Turkey obtained, will throw an exception; However, what's left of this person's income when calculating the tax for the income tax, exceptions have not been an exception, taking into account the tax rate, such as uygulayabilecektir.
b) A resident of Turkey, article 10, 11 and 12 of this agreement with the 4th paragraph of article 13, in accordance with the provisions of vergilendirilebilen when a revenue in Slovakia, Turkey, this person's income tax, that hit Slovakia is equal to tax paid in will allow it to offset an amount. However such offset, offset vergilendirilebilen in income attributed to Slovakia, shall not exceed the amount of the calculated before tax.
2. Slovakia resident of double taxation will be avoided in the following manner: Slovak Republic, their own resident vergilendirdiği according to the provisions of this agreement in Turkey vergilendirilebilen in income tax can included in the elements; However, the tax paid in the specified base amount equal to tax calculated on an amount of Turkey offset will allow it to. FAILURE to DISTINGUISH article 23 1. Citizens of the State, a Âkit other Âkit State, that other State does the same conditions, especially in terms of identity, citizens can remain on their face or taxation or depends from different or more severe becomes subject to the obligation that relies on or a vergilemeye.
2. the 4th paragraph of article 10, without prejudice to the provisions of a Âkit State Âkit State-owned enterprises of other workplace, carrying out the same activities this other State, other State enterprises faced with a taxation less won't lehe.
3. A Âkit State, a resident of the State one or a few other Âkit by, in whole or in part, directly or indirectly, owned or controlled enterprises in the capital, the first-mentioned State, it may be that they are subject to similar enterprises or State taxation or from different or heavier vergilemeye depend on it and they won't be kept subject to tax liabilities connected to it. 4. This provision, personal or to own a Âkit State resident regarding the States therefore implements personal deductions, taxes and also other Âkit State resident discount in base application is understood to have.
5. Article 9, paragraph 7 of article 11, article 12, subsection 1, clause 6 of the provisions or are they to be applied, with the exception of a Âkit State Âkit State teşebbüsünce other gayrimaddî rights fee paid to a resident of interest, and other payments, in determining taxable profits of that enterprise, the first-mentioned State in the same circumstances in which these payments to a resident as your deductible could be made.
Article 24 MUTUAL AGREEMENT PROCEDURE 1. A resident of the State of Âkit, Âkit, from the operations of one or both of the provisions for which this Agreement that does not create a taxation created or have to, this depends on the application procedures prescribed in the domestic legislation of States, without the event, is a resident of the State authorities or State Âkit 23 according to paragraph 1 of the present article falls to the competent authority of the State, is a citizen of Âkit arzedebilir. Where applicable, Âkit should be made within the period specified in the domestic legislation States. 2. The competent authority, any objections will not find a satisfactory solution in its own right, and is not fit for the purpose of this Agreement vergilemeyi in question, by mutual agreement with the competent authority of the State, other Âkit the event in order to will strive to solve.
3. Âkit States competent authorities, the agreement of all kinds of difficulties resulting from the implementation or by comment or reluctance from the efforts to solve the mutual agreement. Authorities at the same time, not addressed in the agreement resulting from the Elimination of double taxation, for which they can consult each other.
4. Âkit States ' competent authorities, matters stated in the preceding paragraph to reach an agreement, they can communicate directly with each other. To reach oral agreement, when deemed necessary, to exchange views on this meeting, representatives of the competent authority Âkit States through a Commission can be executed.
Article 25 EXCHANGE of INFORMATION 1. Âkit States ' competent authorities, which is necessary for execution of the terms of this agreement or discord with the Agreement unless the agreement fall within the scope of the provisions of domestic legislation dealing with taxes is required for the execution of the operational information subject to change. Exchange of information is not limited to article 1. Any information received by a Âkit State, within the framework of their internal legislation of the State, such as information obtained will be kept confidential and only those incurred or debited of taxes as set forth in the agreement or compulsory execution or punishment and this user and/or complaints and appeal jurisdiction to persons or authorities (including judicial authorities and administrative organizations) verilebilecektir. That person or authority such information only in accordance with these purposes. That person or authority such information in court proceedings or in judicial decisions can announce when importing. 2. the provisions of paragraph 1, in no way a Âkit State: a State's legislation or Âkit or other) administrative administrative measures to comply with the application; b) by itself or other Âkit within the framework of the State legislation or normal administrative operations can not be obtained information;
c) any commercial, industrial, professional secret or trade process, or information that makes public aleniyeti public order contradicts information under obligation to be interpreted in a way.
Article 26 DİPLOMAT HÜVİYETİNDEKİ OFFICERS and CONSULAR OFFICERS of these treaty provisions, hüviyetindeki officers or diplomats, consular officers general rules of international law and the provisions of the special agreement affords will not affect financial privileges.
Article 27 ENTERING into FORCE 1. This agreement will be approved and consent documents as soon as possible....................... ' will be the bedrock.
2. The agreement will enter into force after ratification of the litigation, and provisions:
in terms of the taxes withheld at the source a), followed by the date of entry into force of this agreement, the first day of January or later to the stakes paid or offset; and b) other taxes following the entry into force of this agreement in terms of date on or after the first day of January of the taxation year shall for that start.
Article 28 DON'T WITHDRAWN FROM this agreement will remain in effect until it is terminated in a Âkit by the State. Âkit entry into force of the agreement, each of Us, a five-year period from the date of any calendar year beginning after the expiry of at least six months before the end of the diplomatic channels may terminate the agreement by giving a written dissolution advice. In this case the taxes withheld at the source: a Contract) notice of termination is given in terms of calendar years after the end of the paid or the amount of the offset; and b) other taxes, termination notice is given of the calendar year beginning after the end of the taxation year of the provisions for the expression.
THESE CONSIDERATIONS WARRANT, the undersigned have signed this agreement, delegates full authority and seals of vazettiler.
Thomas, Slovak and English languages, all three texts being equally authentic,...........,......................., too. In case of discrepancy between the texts, the English text shall prevail.
On BEHALF of the SLOVAK REPUBLIC of the REPUBLIC of TURKEY
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