News Share

The Tax Hub

Daily Tax Newsletter

Canada; Turkey

27 July 2011

Responsive image

Treaty between Canada and Turkey – details

Details of the income and capital tax treaty and protocol between Canada and Turkey, signed on 14 July 2009, have become available. The treaty was concluded in the English, French and Turkish languages, each text having equal authenticity. The treaty generally follows the OECD Model Convention.

The maximum rates of withholding tax are:

-   20% on dividends in general (Art. 10(2)(b) of the treaty) and 15% if the beneficial owner is a company (other than a partnership) which holds directly shares representing at least 10% of the voting power of the company paying the dividends (Art. 10(2)(a) of the treaty);
-   15% on interest (Art. 11(2) of the treaty); and
-   10% on royalties (Art. 12(2) of the treaty).

Deviations from the OECD Model include that:

-   the term "permanent establishment" also encompasses:
-   a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only if such site, project or activities continue for a period of more than six months (Art. 5(3)(a) of the treaty); and
-   the furnishing of services, including consulting services, by an enterprise of a contracting state through employees or other individuals engaged by the enterprise for such purposes in the other contracting state, but only where such activities continue (for the same or a connected project) within that state for a period or periods aggregating more than 183 days within any 12-month period (Art. 5(3)(b) of the treaty);
-   the term "royalties" includes payments for the use of, or the right to use of recordings for radio and television, and industrial, commercial or scientific equipment (Art. 12(3) of the treaty);
-   the treaty contains a provision regarding independent personal services based on Art. 14 of the UN Model Convention (Art. 14 of the treaty);
-   pensions and annuities arising in a contracting state and paid to a resident of the other contracting state may be taxed in that other state (Art. 18(1) of the treaty); and
-   the term "dividends" in the case of Turkey shall also include the income from investment funds and investment trusts (Para. 6 of the protocol).

Both countries provide for the credit method to avoid double taxation (Art. 23(1) and (2) of the treaty).

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Crosss Border Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment Streams.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More