PROTOCOL
At the moment of signing the Convention between the Czech Republic and the Republic of Turkey for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following provisions which shall form an integral part of the Convention.
(1) In the computation of the periods mentioned in sub-paragraph (b) of paragraph (1) of Article 14, the following days shall be included:
- (a) all days of physical presence including days of arrivals and departures, and
- (b) days spent outside the State of activity such as Saturdays and Sundays, national holidays, holidays, and business trips directly connected with the performance of the activity of the recipient in that State, after which the activity was resumed on the territory of that State.
(2) In the computation of the periods mentioned in sub-paragraph (a) of paragraph (2) of Article 15, the following days shall be included:
- (a) all days of physical presence including days of arrivals and departures, and
- (b) days spent outside the State of activity such as Saturdays and Sundays, national holidays, holidays, and business trips directly connected with the employment of the recipient in that State, after which the activity was resumed on the territory of that State.
(3) The term "employer" mentioned in sub-paragraph (b) of paragraph (2) of Article 15, means the person having right on the work produced and bearing the responsibility and risk connected with the performance of the work.
(4) The term "any other similar organ of a company" mentioned in Article 16 includes, for example, the supervisory board of a company.
IN WITNESS WHEREOF, the undersigned, being duly authorised thereto, have signed this Protocol.
DONE in duplicate at Ankara this twelfth day of November 1999 in the English language.
FOR THE CZECH REPUBLIC:
PAVEL MERTLIK
FOR THE REPUBLIC OF TURKEY:
SUMER ORAL