Period: 21 Legislative Year: 1 Warning: You Are Viewing The Law, Parliamentary General Assembly Accepted. If It Does Not Contain Any Changes That Are Made Later. The Government Of The Republic Of Turkey And The Government Of The Russian Federation Search

Original Language Title: Dönem : 21 Yasama Yılı : 1 Uyarı: Görüntülemekte olduğunuz Kanun, TBMM Genel Kurulunda kabul edildiği halidir. Varsa daha sonra yapılan değişiklikleri içermemektedir. TÜRKİYE CUMHURİYETİ HÜKÜMETİ İLE RUSYA FEDERASYONU HÜKÜMETİ ARA

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Period: 21 Yunder: 1

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


UNDERSTANDING THE PREVENTION OFÇÝFTE

PREVENTINGÇÝFTE

PREVENTING CONFLICT BETWEEN THE GOVERNMENT OF THE TURKISH REPUBLIC AND THE RUSSIAN FEDERATION">

THE DECISION TO PREVENT APPLICABLE FOUND

LAWKANUN

Kanun # 4426

 

Accepted Date: 30.7.1999

MADDE 1. -"Agreement between the Government of the Republic of Turkey and the Government of the Russian Federation under the Government of the Government of the Republic of Russia to Prevent the Agreement on Preventing Double Taxation of Tax on the Land of the Russian Federation".

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.

 

 

 

RUSSIAN FEDERATION OF TURKISH GOVERNMENT

AVOIDING CONFLICT BETWEEN THE GOVERNMENT

TURKISH REPUBLIC GOVERNMENT

AND

RUSSIA FEDERATION GOVERNMENT

received over Revenue isteðiyle

UNDERSTANDING THE FOLLOWING:

UNDERSTANDING THE FOLLOWING:

INCLUDES:

CONTAINS 1

, which prevents double taxation in taxes and is in a statement that }

KAPSAMÝLÝÞKÝN

This information will be applied to the response of taxation, one or both of the states.

ARTICLE 2

KAVRANAN VERGALS

1.  This information will be applied to taxes received over revenue in a FUEL STATE.

2.  All taxes received over the total revenue or revenue items, including taxes levied on earnings from the transfer of securities or real estate, will be considered tax on income.

3.  The applicable taxes are particularly applicable when applicable:

a) Revenue from the Russian Federation under the direction of the Russian Federation, and taxes on earnings over earnings;

i) " The service and the taxes on earnings from institutions "; and

ii)" Income tax from real people ";

(will refer to this as" Russian Tax ");

b) Republic of Turkey ;

i) Revenue Tax,

ii) Corporate Tax and

iii) Funds raised over Income Tax and Institutions Tax,

(This will be mentioned as "Turkish Tax").

4.  At the same time, it will also apply to taxes that are in addition to or replace existing taxes after the date of signing of the statement, or in income that is substantially similar to or substantially similar to the current taxes. The competent authorities of the Aşit States will report to each other the key concerns required by the applicable tax regulations, which are required by the implementation of this statement.

MADDE 3

GENERAL DEFINITIONS

1. The terms

a) "A" State "and" other in the State "mean the terms of the Russian Federation (Russia) or the Republic of Turkey (Turkey), as the term refers to the text:

a)" alisn="JUSTIFY "> b) The terms "Russian Federation" and "Republic of Turkey" refer to the country's territory, its territorial waters, and in accordance with international law in accordance with the country's border with the country;

c) The term "tax" is a sense of taxes in the 2 nci clause of this Meaning income;

d) refers to "Kishi", a real person, a company, and any other set of installations;

e) The term "February" is treated as an institution in any institution or taxation direction. herhangi

f) The term "registered center" means the legal center that is registered in the direction of Turkey, according to the Turkish Trade Code;

g) "A policy of the State of the Aper" and "the other" "By the state of the state," a State of the State will be used by the government. A contact is being pushed out and a contact is being pushed out by the Department of the Dikit's Government;

h) The term "international traffic" is the only ship, vapur, aircraft or land transport that is being made available in the same way as the "Internationalized traffic". The ship, vasaur, aircraft or land transmission vaulted, except for the transfer process.

i) "Authority":

i) in the direction of the Russian Federation-Finance Minister or its authorized representative;

ii) the Republic of Turkey the term-

expressed;

j) The term" real beneficiary " is the price, interest and informal right of a third country's interest in Russia or Turkey. It will be interpreted in the case that it will not be allowed to take advantage of this tax, but this will not apply to the muid of the States in any way.

2.  As a result of implementation of this statement on any date by the State, a defined term of the term text does not otherwise stipulate, unless otherwise, the purposes of a State of the Union tax on the purpose of the state. The meaning of this state in the current tax legislation will have a sense of superiority over the meaning given to this term.

MADDE 4

MUKİM

1.  For the purposes of this statement, the term "part of a Instrument State" means the taxpayer, due to the state of the house, residence, management place (record center), or any criteria similar to that state.

2.  1 The state of the following will be determined by the state of the 1st storm provisions, and will be determined by the state of this winter:

a) this is the state of the state where there is only a permanent state. Will be accepted. If this is a permanent residence in both Develes, it will be considered a mystery (central to the life of life);

b), if its personal and economic relations are more closely related. if there is no State that is the center of the vital interests of the business, or if there is no liability for both of the Azoys, the state of the state where the home is not the only one, will be accepted;

c) If there is a home where the Eater is found to remain in both Devlette, or both If such a house is mentioned in the state, it will only be accepted by the state of the state that it is a citizen;

d) The authority of the Republic of America, if both states are citizens or citizens of both State. authorities will resolve the issue with the understanding.

3.  1 shall be considered a concient of the State of the state in which the legal center is located, as a part of the real part of the 1st fikra provisions, as well.

MADDE 5

SUBTERTION="JUSTIFY"> 1.  The term "workplace" for the purposes of this statement comes to a fixed place in which a State team of the United States has executed a whole or a part of the Âkit Government.

2.  The term "workplace" is especially covered by the following:

a) Management location;

b) Feb;

c) Bureau;

d) Factory;

e) Workshop, and

f) Any location where the maden stove, oil or natural gas well, overflow or natural resources are roped in;

3.  For the purposes of this statement:

a) An eight-month period of continuing construction, construction, assembly or installation or surveillance activities related to them will be a place of office. The construction of the contractor is starting from the date of the construction of the construction site, including the preparation of the construction. In the calculation of the 18 month period, the temporary admission date of this type or project is taken into consideration as the date of the construction of the construction or project of the project. The time period between the temporary acceptance date and the expiration period will not be considered in the calculation of the 18 month period.

b) After the entry of this section, each of the Republic of America has a state or state (a). If they have agreed to a longer period of time for the activities mentioned in the statement, the competent authorities of the Akit States will decide (a) the extension of the time specified in the statement.

4.  Any prior provisions of this clause will be considered to include the term "workplace":

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

b) The goods or trade assets belonging to the community are only acquired for storage, contact, or delivery purposes;

c) Inventory of commodity or trade assets that belong to the business. retention with the purpose of running;

d) How a fixed location is only available for purchase or collection of goods or commerce users;

e) A fixed location for the business of a fixed location is intended for the service, or the half-character elde

f) to achieve only one or more of the activities mentioned in a fixed location (s), e) and e) to perform one or more of the following activities; however, this your collective activity as a result of performing activities together It is either ready or half-character.

5. In an event that applies to 1st and 2nd fikra provisions, a business of -6 may be applied-in an event that acts on behalf of a State of the Akitel State, if the State of Turkey acts on behalf of the state of the government and does not flow with the name of a device in this State. If he has the authority and uses this authority from the mutaden, the company's actions are not described in the 4th forum, but this was the first state in the state to be first mentioned in any activity in which this city was originally due to operate as a result of the operation. The owner will be accepted. However, activities carried out from a fixed location within the framework of the planned storm provision will not make this place a place of office.

6. A policy will not be considered as an owner in this state because it is executing a state in an ongoing trader, general commission agency, or any agency that may be in its own business, only if it is in its own business.

7. A company that is a member of the State of a âite, or if it is controlled by it or is controlled by it, is controlled by or controlled by a company, which is a member of the state, or in commercialized activity in this other state. will not generate 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 "real estate", in any case, is a real estate property, real estate owned by the real estate, the tools and animals used in agriculture and forestry, and other branches of real estate that applies the provisions of domestic legislation. will cover the rights of the inversion rights and the mine quarrying, whether it is fixed or stable, whether the resources and other sources of the resource are to be pushed or to be pushed out. Ships, vassars, planes and land transport will not have any real estate assets.

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 and the proceeds from real estate assets that are used in the invention of real estate.

MADED\NTERNC_MGMT 7

TOTAL EARNINGS

1. An earnings call from a member of the other in the World of Love, in the first place, was first mentioned in the event that the winner was acquired by a site in this state, and only to be attributed to the activities of the workplace. It can be taxed in the state.

2. In the event of an office in the State of the Republic of Azite, to remain withheld by the 3rd fikra provisions, both in the Azite State, the same place, the same or similar conditions under the same conditions, the same or similar conditions under the same conditions as the same. If the total number of activities that are in similar activities, completely separate and in a different way than the one that has been started, will be attributed to what will be achieved, a similar amount will be attributed.

3. When determining a location, you will be allowed to download expenses that are in place for the purposes of the office, including the management and general administration expenses, which are located at any location, or anywhere else in the space.

4. No proceeds will be made available to the office of this location only if it has been received by goods or commercials.

5. The provisions of this clause will not be affected by the provisions of this clause, as the benefit covers the revenue elements that are organized separately.

MADDE 8

DENY, AIR, AND KARA BYTAÞIMACILIÐINDAN

RECEIVED EARNINGS

1. In the first mentioned State of the Republic, the acquisition will be taxed in the first ever mentioned State of the Union traffic. However, the benefit may be taxed in the Profitable State and the State of the State, but the tax will be reduced to 50 per cent of the tax on such earnings.

2. In the first ever mentioned State, the proceeds will be taxed on the State of the World, in which the first ever mentioned State will be taxed at the State of the Azoit State.

3. The payments made by 6 ncu and prior to the previous fakra provisions of this Article are the payment of a ship or flight to a member of the State of the Republic of Turkey, subject to the first mention of the tax return on the State of the State. to be held.

4. The 1st and 2nd fikra provisions will also be applied to a partner, an associate, or any proceeds from an international agency.

MADDE 9

PROBABLE ARRIVAL FIXES

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

b) a Âkit State community, or indirectly, indirectly, or indirectly, in the case of a Âkit Government, or indirectly, a Âkit State community, or indirectly. katýldýðýnda

, and both, both, and financial relations between the two and two buses, are in the management, control or capital of the Akit State community, both of which need to be involved in the development of governance, control or capital. 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. One of the benefits of one of the State's own countries, including the benefit of taxation, may also include the earnings of one of the other State-to-Tax states that are taxed in the country's Profitable State, which is tax-free. At the same time, this first mentioned state of the state, including the benefit, the reported gain, and the people who were going to be among the people who were going to be among those first-mentioned calculations, were subsequently determined as a result of the calculations that were first mentioned in the State. It could be If such a situation occurs, the other state will have to make the necessary corrections to the amount of tax received over the benefit of this regulation, if the state has the opinion that this regulation is right. When making this correction, the authorities of this Union will be kept in mind 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 that the company that made the dividend payment is a member of the government and the legislation of this state; however, the real beneficiary of the dividend is the tax that will take place in this way. The gross dividend will not address 10 percent of the amount.

3. The term "dividend", used in this material, is the state of taxation, based on the legislation of the state, which is based on revenues from other rights, which may not be in stock or credit, and the company that makes the profit off of the profit. Refers to revenues from other companies that receive the same treatment as revenue from their stocks.

4. The acquisition of a company with a State of the Republic of the Union in which it was found in the event of an office in the company of Turkey, in which it was taxed, according to the State of the Union, and the State of the State, after being taxed according to article 7 of the state. taxable for the rate specified in the 2 nci plug on the part of the system.

5. The true beneficiary of the dividend, which is a State of the Combat Government, is a stable site in Russia, where the company that pays the dividend is found to be involved in commercial activity, or if it is found, or a Turkey-based fixed place in Russia. if they are found in free professional activity and such themes may be attributed to this site or fixed place, the 1st and 2nd fikra provisions will not be applied. In this case, according to the event, the 7 nci or 14th provisions of this statement will apply.

ARTICLE 11

FAİZ

1. The interest paid to a member of a Âkit Camel and a member of the other State can be given in this language.

2. However, this interest may 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 fikra provisions:

a) the interest paid to the Government of Turkey and the Central Bank of Turkey or the Central Bank of Turkey or the Turkish Eximbank will be exempted from Russian tax;

b) in Turkey The interest paid to the Russian government or to the Russian Central Bank or to the Russian Foreign Trade Bank will be exempted from the Turkish tax.

4. The term "interest" used in this material is premium and bonuses for securities, bonds, and debt denominations, which are derived from all types of credulants, as well as revenues from bonds and debt securities, especially public securities. The revenue generated by the revenue, including the tax legislation of the State in which the revenue was obtained.

5. The true beneficiary of the interest in a Kite State team is that it is engaged in commercial activity, or if found in the commercial activity of a site in the country where interest is obtained, or a Turkey constable, a fixed place in Russia. If there is an active interest in this office or fixed site, the 1st and 2nd fikra provisions will not be applied if found in the activity of the subject and the payment of the subject of the subject. In this case, the provisions of this article will apply the provisions of article 7 or 14th.

6.  The Government of a State Government, regional or local government, or the interest paid by a member of this State shall be considered to be acquired in the state of the âite. 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. This will be considered to be acquired in the Policy Policy, where the location, location, or fixed location is located.

7.  The amount of interest paid in the credit is due to the fact that there is no such relationship, because of the actual beneficiary of the payable or the real beneficiary of both, or both, and the amount that will be determined between the beneficiary and the leper. 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 amount of non-ligent rights paid to a member of a Akkit State and Devlet State may be taxed at this other State.

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, but the real beneficiary of the non-diligent right-price is the tax, which will be tax, It will not take 10 per cent of the gross amount 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. Use of the model, plan, secret formula, or production method, or use of information in financial, commercial or scientific experience, use or sell or use scientific or scientific equipment, or use of scientific or scientific equipment. covers all kinds of payments.

4.  The true beneficiary of the cost of an Akit State is a real beneficiary of the price of a fixed place in Russia, with a stable site in Russia, or a Turkey-based fixed location in Russia. If it is found in the activity and there is an active view of this office or fixed site with the right or the right to be paid, the 1st and 2nd fikra provisions shall not be applied. In this case, the provisions of this statement will apply the provisions of Article 7 or 14th.

5.  The Government of a State Government, regional or local government, or the government of this Azite State shall be deemed to have achieved the price of invigorated rights paid by a member of the State of the World. 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 being 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.

ARTICLE 13

CAPITAL CAMEL INCREASE EARNINGS

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.  A Stock State's policy is to be used to dispose of securities owned by a property owned by a company or a fixed site that is used to perform free business in the other state, a State government said. The benefits may be taxed in this other State, including the benefit of an overhaul of this location or fixed site.

"The term" security " is defined in the legislation of the entity in which it is found. statements made.

3.  The proceeds from an overhaul of the ship, aircraft or land transmission services, or activities related to the activities of the State of the Republic of Turkey, have been issued to international traffic, said the proceeds, only to be overseen by the company. will be taxed.

4.  Earnings from an overhaul of shares or securities, bonds, bonds, and so on in a company will be taxed only in the Fuel State, which is the only person to whom it is a muchless muchas. However, the resulting capital gains in the above sentence and the resulting capital gains in the other Âkit Devlette will be taxed in the other State if 1 year of loss of power and disposal are not 1 year.

MADADE 14

FREE PROFESSIONAL FAIL-THROUGH

OBTAINED

1.  The revenue of a real person who is a member of the State of a State is due to the activities of free profession or other activities, if not, or not, or otherwise, in the other Devlette. If it is owned and cannot be assigned to a fixed location that is continuously available, it will be taxed only in this state.

2.  The term "free trade activities" is a scientific, religious, artistic, educational, educational and educational activities that are carried out in particular as a result of the response of doctors, lawyers, engineers, architects, workers and accountants. scope of activities.

ARTICLE 15

OBTAINED FROM THE RESULTS

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, the revenue of a Profit Government has been achieved through an ongoing service in the State of the World:

a) Revenue resulting in one or more of the calendar year related calendar years. the maximum of 183 days in total, and

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

c) Payment, issuer in the other in the yalnýzca

only if it has not been done from a location or fixed location will be taxed in the first mentioned Devlette.

3.  The charges and other revenues obtained from an Ekit State team, performed by 1 pearl and 2 ci fakra provisions, are the charges and other proceeds of this service:

a) The 5th of this section is A ship, aircraft or land transport in international traffic is related to the 3rd party (a) project, construction, assembly, or installation project, and

b) a city of Aşit State. ilgili

this language is related to the work performed in the not taxable.

4.  The payments made from the resources of this other State by a journalist or reporter who is in the case of a State of the Azite state, regardless of the 1st and 2nd fikra provisions, immediately prior to the visit or visit of a State of the Republic of Turkey, were a 2-year period. , for example, the first mentioned state will be exempt from the data.

ARTICLE 16

PAYMENTS TO PRINCIPALS

Any company or other company with a Liable State team of any kind. with the fact that a legal entity is a member of a board or similar body Fee-like payments and other such payments may be taxable in this language.

ARTICLE 17

ENTERTAINERS AND ATHLETES

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.  The artist or athletes who are the team of the State of a âite derive their activities from the activities they perform in the Devlet Devlette, supporting public funds belonging to the other State, regional or regional administrations of the visit. , in the event, the data will be made available in the other state.

ARTICLE 18

RESULTS FROM PUBLIC TASKS

1.  a) The payments made by the State, regional or local government, and any remaining payments due to the government's government, regional or local government, and the government of a Fallen State to the Government of the Republic of Turkey. this will be taxed only.

b) However, the following service is a member of this state, in which case it was granted and paid for, such payments are only in this other, in the Devlet Devlette. will be taxed However, this is not a citizen of the state;

i) is a citizen of this State;

or

ii) are not citizens of the first mentioned state, but only to perform this service. için

is mandatory.

2 is not in the process of having this state switched to a position of this State.  a) Once services given by a real person to a SUICIDE STATE, regional or regional administration, this State, regional or local government, or pensioners who are paid for by the funds generated by them are only in this State. taxable.

b) However, if the actual person is a member of the Government and its citizens, then the other retired people will be taxed at the other Akitit State.

3.  A State of the State itself, regional or local government, and pensions, which are provided by the services of the regional or local government, are not the provisions of 1 and 2 fikra provisions of this Article, which are provided by the regional or local government. The provisions of clause 15, 16, and 19 will be applicable.

RETIREES

The provisions of the 2nd section of the pearl clause are intended to remain in a Possession State for a time of life. Pensions, and similar payments, paid in this state, are only in this State. taxable.

ARTICLE 20

ACCOUNTS, INTERNSHIPS, FACTORS, AND

PAYMENTS TO AGENTS

1.  In the event of a visit to the State of Azor, or immediately before, in the case of the other State of the Republic, the first mentioned State is a student or an intern with the purpose of life, or to be an associate, or colleague, or colleague, or colleague, or colleague. The payments made from sources first mentioned so that they can be sold will not be taxed in the first mentioned Devlette.

2.  In the same way, a two-year-old scholar or agent who is in the case of a State of the Republic visit, or in the case of the other State of the World immediately preceding it, is a member of the State of the United States, whose aim is to pay for or to conduct a search. for periods of time, the revenues that are obtained and the data obtained will be the exception that will be made in this State if such payments are made from sources in this country's current state.

MADPLACE 21

FOREIGN STATES

Where a Sense of State does not exist, it is the revenue elements that are not specified in earlier articles of this state, only in this State. You will be taxed.

TAX DATAVERGÝLENDÝRMENÝN

A Profit State is a taxable income that can be taxed in accordance with the provisions of this Anger This is the first to mention the tax on the income paid in this Devlette. It can be ruined by the verbally. However, the amount of the subject matter will not be subject to the tax amount calculated in accordance with the tax code of the first mentioned state for this revenue.

ARTICLE 23

FAILURE TO DO "> NOT TO 1.  The citizens of a State Government, in the same way, are responsible for taxes, especially in the direction of the government, or the liability, especially in the direction of the government, of the country's citizens, in particular, in the case of taxation and the need for a greater amount of taxation. They will not be subjected to taxation and to those who are not. This provision will also be applied to the non-connoctions of one or both of the states, or both, with the provisions of the 1st clause.

2.  In order to hide the 4th fikra provisions of the 10th Amendment, a State of the Republic of Turkey, which has a business in the country of Turkey, operates the same activities as the other State, in relation to the income that can be attributed to the company. They will not be subject to a higher taxation than their contact or third State.

3.  Any provision of this material will not be understood as to which a Power State has to apply discounts, taxes, and matrah discounts to their own party, as well as in the case of the Akit Government.

4.  The interest of a State of the Republic of Turkey, excluding the provisions of the provisions of the 7th section of Article 11, of the 7th of the 11th Article, or 6 of the 12 articles of Article 9, is the interest paid to a member of the State of the Republic of Turkey, the interest of the non-figureed rights and the In the determination of the taxable earnings of this private payment, these payments may be reduced as if they were made to a member of the State originally mentioned in the same conditions.

5.  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 taxation or otherwise, subject to taxation or otherwise.

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. The state of the state may be in charge of the state, which is the condition of the state. The following is a three-year term from the initial declaration of a non-compliance with the provisions of the Sovereign. In the course of Turkey, the authority must be in charge within a year from the first declaration of the applicable taxation that is not applicable to the provisions of this Statement. However, during this period, the individual will be able to aspire to the competent authority of Turkey within a period of five years from the first day of January, following the applicable taxation period. The corresponding taxation year is the result of revenue that is subject to the event that does not comply with the applicable provisions.

2.  If a satisfactory solution is not resolved, the competent authority will strive to understand the country's competent authority, in an effort to avoid a further taxation of the State.

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 competent authorities of the State States can communicate with each other in order to reach an understanding of the issues outlined in the previous series of frisks. 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.  The competent authorities of the State States are required to enforce the provisions of the internal legislation relating to the applicable taxes, unless they have the information or the information required to enforce the provisions of this Statement. They're going to put the information on my desk. 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 administration) for the complaints 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) No administrative measures to comply with the legislation or administration practices of the State or the other,

b), or the other Aper Device 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 GOVERNMENT and

CONSULAR OFFICERS

The provisions of this statement are provided by officers or consular officers on the diplomat's government. The benefits of the law will not affect the financial details of the law or the provisions of special understanding.

ARTICLE 27

EFFECTIVE LEAVE

Each State of the Union, this means the effective In order to enter, the following are the plans for the He will inform the other diplomatic means that he has been in diplomatic means. This statement will take effect on the last date of the last of these notices; and

a) the first day of January following the effective date of the current entry, or later paid or later, following the applicable taxes in the resource. for quantities; and

b) Provision Of received taxes over Revenue, first day of January following the effective date of the date, or later taxation periods ofvergilendirme

expression.

MADDE 28

WITHDRAWAL

This means will remain in effect continuously, but only one of the calendar year's June 30th day of any calendar year following the week of approval of the approval documents. Or prior to that, he would be able to give a diplomatic notice to the State of the Aper Transfer, which is a diplomatic means. Do this then:

a) For the taxes that are issued in the resource, the first day of the calendar year following the issuance of the subject of such notice, or for the amounts paid or destroyed later; and

b) The first day of the calendar year after the revenue received over Revenue, for the first day of January or later, for taxation years.

provision remove.

in Turkish, Russian, and English languages, all three text It was held in Ankara on 15.12.1997, to be equally valid. If there are no differences between the text, the English text will be valid.

 

GOVERNMENT OF THE TURKISH REPUBLIC OF THE RUSSIAN FEDERATION