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Turkey - Somalia Tax Treaty (2016, not yet in force) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 3

General Definitions

(1) For the purposes of this Agreement, unless the context otherwise requires:

  • (a)
    • (i) the term "Turkey" means the land territory, internal waters, the territorial sea and airspace above them, as well as the maritime areas over which Turkey has sovereign rights or jurisdiction for the purposes of exploration, exploitation and preservation of natural resources, whether living or non-living pursuant to international law;
    • (ii) the term "Somalia" means the land territory, internal waters, the territorial sea and airspace above them, as well as the maritime areas over which Somalia has sovereign rights or jurisdiction for the purposes of exploration, exploitation and preservation of natural resources, whether living or non-living pursuant to international law;
  • (b) the terms "a Contracting State" and "the other Contracting State" mean Turkey or Somalia as the context requires;
  • (c) the term "tax" means any tax covered by Article 2 of this Agreement;
  • (d) the term "person" includes an individual, a company and any other body of persons;
  • (e) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (f) the term "legal head office" means the registered office registered under the ' related laws of Turkey and Somalia;
  • (g) the term "national", in relation to a Contracting State, means:
    • (i) any individual possessing the nationality or citizenship of that Contracting State; and
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in that Contracting State;
  • (h) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (i) the term "competent authority" means:
    • (i) in Turkey, the Minister of Finance or his authorised representative; and
    • (ii) in Somalia, the Minister of Finance or his authorised representative;
  • (j) the term "international traffic" means any transport by a ship, aircraft or road vehicle operated by an enterprise of a Contracting State, except when the ship, aircraft or road vehicle is operated solely between places in the other Contracting State.

(2) As regards the application of the Agreement at any time by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.