DT19173 - DT: Turkey: double taxation agreement, Article 24: Non-discrimination
(1) Nationals of a Contracting State shall not be subjected in
the other Contracting State to any taxation or any requirement
connected therewith which is other or more burdensome than the
taxation and connected requirements to which nationals of that
other State in the same circumstances are or may be subjected.
(2) Subject to the provisions of paragraph (4) of Article 10
of this Agreement, the taxation on a permanent establishment which
an enterprise of a Contracting State has in the other Contracting
State shall not be less favourably levied in that other State than
the taxation levied on enterprises of that other State carrying on
the same activities.
(3) Enterprises of a Contracting State, the capital of which
is wholly or partly owned or controlled, directly or indirectly, by
one or more residents of the other Contracting State, shall not be
subjected in the first-mentioned State to any taxation or any
requirement connected therewith which is other or more burdensome
than the taxation and connected requirements to which other similar
enterprises of the first-mentioned State are or may be subjected.
(4) Except where the provisions of Article 9, paragraph (7)
of Article 11, or paragraph (6) of Article 12 of this Agreement
apply, and subject to the provisions of paragraph (8) of Article 11
of this Agreement, interest, royalties and other disbursements paid
by an enterprise of a Contracting State to a resident of the other
Contracting State shall, for the purpose of determining the taxable
profits of such enterprise, be deductible under the same conditions
as if they had been paid to a resident of the first-mentioned
State.
(5) Nothing contained in this Article shall be construed as
obliging either Contracting State to grant to individuals not
resident in that State any of the personal allowances, reliefs and
reductions for tax purposes on account of civil status or family
responsibilities which it grants to its own residents.
