Double taxation Treaty rates between TR and other countries

Dividend

TAX RATES TAKEN BY THE RESOURCE STATE FROM SHARE OF PROFITS (DİVİDEND) BASED ON DOUBLE TAXATION TREATIES BETWEEN TURKEY AND SOME OTHER COUNTRIES
COUNTER PARTY STATE	SHARE(%)	TAX RATE (%)

1. AUSTRIA (REVISED)	For Turkey;	5
	a) If at least 25 (On condition that it is subjected to tax exclusion in Austria)	5
	b) All the other cases	15
	For Avustria;	5
	a) If at least 25	5
	b) All the other cases	15

2.NORWAY (REVISED)	If at least 25	5
		5
	In case it is acquired by Norway State Pension Fund(for Norway), or Social Security Fund(for Turkey)

	All the other cases	15

3. HOLLAND (I)	If at least 25	15
3. HOLLAND (I)	All the other cases	20

4. ENGLAND	If at least 25 ( Of franchise )	15
4. ENGLAND	All the other cases	20

5. FRANCE	If at least 10	15
5. FRANCE	All the other cases	20

6. GERMANY (NEW)	If at least 25	5
6. GERMANY (NEW)	All the other cases	15

7. SWEDEN	If at least 25	15
7. SWEDEN	All the other cases	20

8. BELGIUM (II)	If at least 10	15
8. BELGIUM (II)	All the other cases	20

9. ITALY	All cases	15

10. JAPAN (III)	If at least 25	10
10. JAPAN (III)	All the other cases	15

11. U.A.E (IV)	If at least 25	10
11. U.A.E (IV)	All the other cases	12

12. HUNGARY	If at least 25	10
12. HUNGARY	All the other cases	15

13. KAZAKHSTAN	All cases	10

14. INDIA	All cases	15

15. REPUBLIC OF CHINA	All cases	10

16. U.S.A	If at least 10 ( Of franchise )	15
16. U.S.A	All the other cases	20

17. UKRANIA	If at least 25	10
17. UKRANIA	All the other cases	15

18. RUSSIA	All cases	10

19. CZECH REPUBLIC	All cases	10

20. SPAIN	For Turkey ;	5
	a) If at least 25
	(In the manner described in sub-section 5, paid share of profits from revenues which is subject of the tax)
	b) All the other cases	15
	For Spain ;
	a) If at least 25	5
	b) All the other cases	15

21. LUXEMBURG	For Turkey ;
	a) If at least 25	10
	b) All the other cases	20
	For Luxemburg ;
	a) If at least 25	5
	b) All the other cases	20

22. SUDAN	All cases	10

23.QATAR(REVİZED)	If at least 20
	If a goverment authority	5
	All other cases	10

24. IRELAND	For Turkey ;
	a) If at least 25 ( Of franchise ) ((In the manner described in sub-section 5, paid share of profits	5
	from revenues which is subject of the tax)
	b) If at least 25	10
	c) All the other cases	15
	For Ireland ;
	a) If at least 25 ( Of franchise )	5
	b) All the other cases	15

25. NEW ZEALAND	If at least 25	5
	All the other cases	15

26. CANADA	If at least 10 ( Of franchise )	15
	All the other cases	20

27. SWITZERLAND	If at least 20	5
	All the other cases	15

28. AUSTRALIA (V)	For Turkey ;
	If at least 25 (Share of profits paid via revenues subjected to full rate	5
	Corporation Tax in Turkey)	5
	For Australia;
	If at least 10 ( Of franchise )	5
	All the other cases (for both country)	15

29. MALTA (VI)	For Turkey ;
	If at least 25	10
	All the other cases	15
	For Malta ;	Exception
		In some cases 15





(I) According to protocol clauses; Deviation from article 10 subsection 2 subclause a as long as affiliation revenues in Holland is subjected maximum tax rate will be 5% in Holland, 10% in Turkey.
(II) According to protocol clauses maximum put into practice 5% in Belgium, 10% in Turkey.
(III) The conditions indicated in the protocol tax rates in Turkey will be performed in order 15% and 20%.
(IV) The one who gain share of profit in case it belongs to public enterprise of other contracting State Government or all other State Government or all other contracting State or it’s political subdivisions, or local administrations will practiced 5%.
(V) According to protocol clauses; Without looking rate restriction on Article 10 Subsection 2, and suclause (a)(ii), in case share of profits subjected to taxation in Australia, Turkey can obtain 15% from these share of profits. Without looking rate restriction on Article 10 Subsection 4, and subclause (a), the revenues which can be imputed to a resident company in Turkey is subjected to taxation in Australia, Turkey can obtain taxation from this amount in a rate without exceed 15%.
(VI) According to clauses Article 10 Subsection 2 subclause (b), distributed revenues, as per clauses financial supports made in industry in Malta, income of the company or the revenues belongs to the year financial support is made, company supported, for income in the year of assesment subjected to Maltian taxes, tax declaration to Malta Tax Office and in a condition presenting accounting records, Maltian taxes from distributed revenues, will not exceed 15% of these revenues.

Royalty

TAX RATES TAKEN BY THE RESOURCE STATE FROM ROYALTIES BASED ON DOUBLE TAXATION TREATIES BETWEEN TURKEY AND SOME OTHER COUNTRIES
COUNTER PARTY STATE	TAX RATE (%)

1. AUSTRIA (REVISED)	10

2.NORWAY (REVISED)	10

3. HOLLAND	10

4. ENGLAND	10

5. FRANCE	10

6. GERMANY (NEW)	10

7. SWEDEN	10

8. BELGIUM	10

9. ITALY	10

10. JAPAN	10

11. U.A.E	10

12. HUNGARY	10

13. KAZAKHSTAN	10

14. INDIA	15

15. REPUBLIC OF CHINA	10

16. U.S.A	5-10

17. UKRANIA	10

18. RUSSIA	10

19. CZECH REPUBLIC	10

20. SPAIN	10

21. LUXEMBURG	10

22. SUDAN	10

23.QATAR(REVİZED)	10

24. IRELAND	10

25. NEW ZEALAND	10

26. CANADA	10

27. SWITZERLAND	10

28. AUSTRALIA (V)	10

29. MALTA (VI)	10

This publication has been prepared for informational purposes only. None of information contained in this publication shall constitute legal, tax, accounting advice.