in Turkey i. the income tax;
in Turkey a) Subject to the provisions of the laws of Turkey regarding the allowance as a credit against Turkish tax of tax payable in a territory outside Turkey, Austrian tax payable under the laws of Austria and in accordance with this Agreement in respect of income (including profits and chargeable gains) derived by a resident of Turkey from sources within Austria shall be allowed as a deduction from the Turkish tax on such income. Such deduction, however, shall not exceed the amount of Turkish tax, as computed before the deduction is made, attributable to such income.
in Turkey as respects any taxable periods beginning on or after the first day of January in the year next following the date on which this Convention enters into force.
in Turkey. (i) with regard to taxes withheld at source, in respect of amounts paid or credited on or after 1 January next following the date upon which this Convention enters into force;
in Turkey. Rice, the United States claimed that Turkey discouraged full utilization of the tariff rate quota on rice by requiring license applicants to comply with a domestic purchase requirement. The Panel declined to rule on the US claim under Article 3.5(h) as it had ruled that the domestic purchase requirement violated Article III:4 of GATT 1994.16
in Turkey. Textiles, the Panel noted (in relation to the notification requirement of Article 2.1) that "since the purpose of the ATC is to provide exceptions to the general application of Articles XI and XIII of GATT during an integration period to be completed by 1 January 2005, these exceptions should be interpreted narrowly".3 V. ARTICLE 2
in Turkey. Textiles, the Panel found that Article 2.1 established a mandatory requirement to notify all MFA restrictions within a 60-day time window after entry into force of the WTO Agreement. The Panel noted that all Members that could notify such MFA-derived restrictions had done so, and no others could be notified later: 5 G/TMB/R/60, para. 29. 6 G/TMB/R/60, para. 30. "The lists of restrictions notified pursuant to Article 2.1 set the starting point for the treatment of the restraints carried over from the former MFA regime. Four WTO Members notified the TMB pursuant to Article 2.1 of the ATC: Canada, the European Communities, Norway and the United States. We consider that the notification requirement of 60 days referred to in Article 2.1 of the ATC is mandatory both for formal and substantive reasons. The wording of Article 2.1 is unequivocal with the use of the term "shall". Moreover, since the purpose of the ATC is to provide exceptions to the general application of Articles XI and XIII of GATT during an integration period to be completed by 1 January 2005, these exceptions should be interpreted narrowly.7 Stemming from this provision, only the four Members above had the right to and did notify measures which allowed them to maintain MFA-derived quantitative restrictions for a maximum period of 10 years during which import quotas must increase annually until the products they cover are integrated into GATT. In the absence of an exception under the ATC or a justification under GATT, no new quantitative restrictions introduced by a Member can benefit from the exceptions provided for in Article 2.1 of the ATC after this 60 day period."8
in Turkey as respects any taxable periods beginning on or after the first day of January in the year next following the date on which the period specified in the said notice of termination expires.
in Turkey. For taxes with respect to every taxable period beginning on or after the first day of January of the year next following that specified in the said notice of termination. In witness whereof the undersigned, duly authorised thereto, have signed this Convention. Done in duplicate at Lisbon this eleven day of May, 2005 in the Portuguese, Turkish and English languages, all texts being equally authentic. In case of any divergence of interpretation or application of this Convention, the English text shall prevail. FOR THE PORTUGUESE REPUBLIC: Xxxx Xxxxxx e Xxxxx Minister of State and Finance FOR THE REPUBLIC OF TURKEY: Xxx Xxxxx Undersecretary of the Ministry of Foreign Affairs PROTOCOL At the moment of signature of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income concluded this day between the Portuguese Republic and the Republic of Turkey, the undersigned have agreed upon the following additional provisions, which form an integral part of the Convention. Ad Article 6 With reference to Article 6, it is understood that the provisions described therein shall also apply to income from associated movable (personal) property and from the provision of services for the maintenance or operation of immovable property (real property). Ad Article 8 For the purposes of paragraph 2 of Article 8, it is understood that the provisions of that paragraph include profits of a consortium or a similar form of association as corresponds to the participation held in the consortium or association by a company that is resident of a Contracting State. Ad Article 10 With reference to paragraph 3 of Article 10, it is understood that the term “dividends” also includes: in the case of Portugal, profits attributed under an arrangement for participation in profits (associagao em participacao); in the case of Turkey, income derived from an investment fund and investment trust. Ad Article 12 For the purposes of paragraph 3 of Article 12, it is understood that the term “royalties” includes gains derived from the use of such right or property in the case of an alienation of such right or property to the extent that such gains are contingent on the productivity, use, or disposition thereof. Ad Article 14 With reference to paragraph 2 of Article 14, it is understood that if the enterprise of a Contracting State elects to be taxed in the other Contracting State in accordance with the provisions of Article 7 of this Convention, t...
in Turkey where a resident of Turkey derives income which, in accordance with the provisions of this Agreement, may be taxed in South Africa, Turkey shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in South Africa. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in South Africa, ii) where a resident of Turkey derives income which, in accordance with the provisions of this Agreement, shall be taxable only in South Africa, Turkey may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
