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HMRC internal manual

Double Taxation Relief Manual

Turkey: Tax Sparing

The agreement provides for credit to be given for `tax spared’ (see INTM161270 & 161280) in Turkey under the Turkish laws set out in Article 23(2).

Relief is, however, restricted to tax spared in Turkey for a period of ten years in respect of any one source of income.

It has been agreed that Turkish law 4325 of 1998 is of a substantially similar character to those included in Article 23(2)(a) of the Agreement and tax spared under this law will qualify for credit in accordance with Article 23(2)(b).

Amounts of `tax spared’ for which relief is given should be reported as mentioned at INTM161290.