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HMRC internal manual

Double Taxation Relief Manual

Turkey: Company residence

Where a company is resident in both Turkey and the United Kingdom under the respective domestic provisions it is deemed to be a resident of the country in which it is effectively managed for the purposes of the agreement. Where, however, its registered office address is in one country and its place of effective management is in the other, the agreement makes provision for the residence position to be resolved by agreement between the respective tax authorities.

Any case where such an agreement is required should be submitted to Business International.