In view of the automatic exchange of information on Article 25 and the cooperation on the taxation of Article 26 of the Treaty, we believe that the Treaty will also strengthen financial and diplomatic cooperation between the two countries. 7. If, for any reason, the amount of interest paid is greater than the amount agreed upon by the payer and the actual beneficiary because of a particular relationship between the payer and the actual beneficiary or between the two and another person, the provisions of this section apply only to the amount specified above. In this case, the excess portion of the payments remains taxable under the legislation of each contracting state, taking due account of the other provisions of this agreement. When a person is a tax resident in the United Kingdom and also has a tax seat in another jurisdiction, i.e. a “dual resident,” and if the other jurisdiction has a tax agreement with the United Kingdom, the treaty distributes a person`s income tax and profits between the two countries. Turkey: detailed tax agreement of the current tax agreements between the United Kingdom and Turkey, provided by HMRC. For the purposes of this article, we consider that a person is tax resident in the United Kingdom and resident of an additional country, although double taxation agreements may exist between two countries. 3. The competent authorities of the contracting states try to resolve by mutual agreement any difficulty or doubt about the interpretation or application of the convention. 1. This agreement does not affect the tax privileges of members of diplomatic or permanent missions or consular missions, in accordance with the general rules of international law or the provisions of specific agreements.
3. If, under paragraph 1, a person other than a person resides in the two contracting states, he or she is considered a resident of the contracting state where his or her place of effective administration is located. However, where such a person has the place of effective administration of his activities in one of the contracting states and his statutory seat in the other contracting State, the competent authorities of the contracting states agree that the State party whose resident is owned by the company under this Convention. The treaty will enter into force with the last communication that the respective governments have communicated to each other by official correspondence that the constitutional formalities required by the article 28 provision have been completed. In this context, it is expected that official notifications between countries will be completed by 2020 and the provisions of the treaty will be implemented from 1 January 2021. Double taxation agreements (also known as double taxation agreements) are concluded between two countries that define the tax rules for a tax established in both countries. The Double Taxation Convention came into force on October 26, 1988. The treaty consists of 29 articles and an additional protocol containing two other articles that were signed between two countries in accordance with the OECD model tax agreement between two countries. Accordingly, the first articles contain terms and explanations regarding persons covered and taxes, general definitions, residence and stable establishment, and the other articles contain provisions relating to the prevention of double taxation of taxes on real estate, sea, air and land income, associated companies, dividends, interest, royalties , capital gains, self-reliance and employment.