Avoidance of Double Taxation on Income Derived from Property

According to Article 6 of the ‘Agreement Between the United Kingdom of Great Britain and Northern Ireland and The Republic of Turkey for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains’ dated December 19, 1986;

a) Income derived by a resident of UK from immovable property (including income from agriculture or forestry) situated in Turkey is taxed in Turkey. The associated income may be the direct use, letting or use in any other form of immovable property

b) The term ‘immovable property’ has the meaning which has under the law of Turkey. The term in any case include property accesssory to immovable property, livestock and equipment in used in agriculture and forestry, fisheries, rights to which the provisions of general law respecting landded property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural forces; ships, boats, and aircraft are not be regarded as immovable property.

c) The above provisions also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent services.

According to Article 23 of the aforementioned Agreement, Turkish tax payable under the law of Turkey and in accordance with the agreement, whether directly or by deduction, on income or chargeable gains from sources within Turkey are allowed as a credit against any UK tax computed by reference to the same income and chargeable gains by reference to which the Turkish tax is computed.