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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Turkey: Permanent establishments

Under Turkish law the Turkish branch of a non-resident company is liable to a further tax in addition to normal Turkish corporation tax. Under the agreement the maximum rate at which this further tax may be charged is set at 15 per cent of the profits attributable to the Turkish permanent establishment of the United Kingdom company (Article 10(4)).