Reservations and Declarations for Treaty No.127 - Convention on Mutual Administrative Assistance in Tax Matters

Nature of declaration : Declarations, Denunciations, Derogations
Status as of 25/05/2019

Turkey

Declaration contained in a letter from the Minister of Finance of Turkey, dated 19 October 2011, handed over to the Secretary General of the OECD at the time of signature of the instrument, on 3 November 2011 - Or. Engl. and confirmed in the instrument of ratification deposited with the Secretary General of the OECD on 26 March 2018 - Or. Engl.

The Republic of Turkey declares that it will implement the provisions of this Convention and the Protocol only to the States Parties with which it has diplomatic relations.
Period covered: 01/07/2018 -
Articles concerned : -

Declaration contained in a letter from the Minister of Finance of Turkey, dated 19 October 2011, handed over to the Secretary General of the OECD at the time of signature of the instrument, on 3 November 2011 - Or. Engl. and confirmed in the instrument of ratification deposited with the Secretary General of the OECD on 26 March 2018 - Or. Engl.

ANNEX A – Taxes to which the Convention would apply:

Article 2, paragraph 1.a.i:
- the income tax;
- the corporation tax;

Article 2, paragraph 1.a.ii: --

Article 2, paragraph 1.a.iii: --

Article 2, paragraph 1.b.i: --

Article 2, paragraph 1.b.ii: --

Article 2, paragraph 1.b.iii:
A.: --
B.: --
C.: value added tax.
D.: --
E.: --
F.: --
G.: --

Article 2, paragraph 1.b.iv: --
Period covered: 01/07/2018 -
Articles concerned : 2

Declaration contained in a letter from the Minister of Finance of Turkey, dated 19 October 2011, handed over to the Secretary General of the OECD at the time of signature of the instrument, on 3 November 2011 - Or. Engl. and confirmed in the instrument of ratification deposited with the Secretary General of the OECD on 26 March 2018 - Or. Engl.

ANNEX C – Definition of the term "national" for the purpose of the Convention

All individuals possessing Turkish nationality in accordance with the Turkish Nationality Code, and all legal persons, partnership or association deriving their status as such from the laws in force in Turkey.
Period covered: 01/07/2018 -
Articles concerned : 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 March 2018 - Or. Engl.

Turkey declares that its ratification of the “Convention on Mutual Administrative Assistance in Tax Matters” neither amounts to any form of recognition of the Greek Cypriot Administration’s pretention to represent the defunct “Republic of Cyprus” as party to the Convention, nor should it imply any obligations on the part of Turkey to enter into any dealing with the so-called Republic of Cyprus within the framework of the said Convention.

The Republic of Cyprus was founded as a Partnership State in 1960 by Greek and Turkish Cypriots in accordance with international treaties. This partnership was destroyed by the Greek Cypriot side when it unlawfully seized the state by forcibly ejecting all Turkish Cypriot members in all the state organs in 1963. Eventually, Turkish Cypriots who were excluded from the Partnership State in 1963 have organized themselves under their territorial boundaries and exercise governmental authority, jurisdiction and sovereignty. There is no single authority which in law or in fact is competent to represent jointly the Turkish Cypriots and the Greek Cypriots and consequently Cyprus as a whole. Thus, the Greek Cypriots cannot claim authority, jurisdiction or sovereignty over the Turkish Cypriots who have equal status, or over the entire Island of Cyprus.
Period covered: 01/07/2018 -
Articles concerned : -


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