tax-treaties.com
Choose agreementSOURCE EDITION
Find article

Germany – Turkey · Source editionArticle 23 Non-discrimination

Unreviewed · applicability unverified

(1)

(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States.

PDF page · 14

(2)

(2) Stateless persons who are residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of the State concerned in the same circum- stances are or may be subjected.

PDF page · 14

(3)

(3) The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reduc- tions for taxation purposes on account of civil status or family responsibilities which it grants only to its own residents.

PDF page · 15

(4)

(4) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, in- terest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State.

PDF page · 15

(5)

(5) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burden- some than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

PDF page · 15
Source, edition and limits
Source edition
de-turkey-2012-base | BGBl. 2012 II S. 526 | Signed: 2011-09-19 | Gazette publication: 2012-05-30
Source form
official-publication PDF retained unchanged; reader derives from an evidenced native font-map encoding-recovery derivative, not OCR
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
The original signing clause identifies German, Turkish and English as authentic. Only German and English are supplied; the authentic Turkish version is NOT included. The clause gives English precedence in divergent interpretation of the German and Turkish texts. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-turkey-2012-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2011-09-19; consent law 2012-05-24; Gazette publication 2012-05-30; treaty entry into force UNRESOLVED in pinned audit (retained official-article audit evidence); general application from 2011-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only independently evidenced source font code00 /space Unicode mappings U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyphs, 278-unit advances, unchanged decoded page content streams and 22/22 identical page renders evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No generated treaty wording and no OCR.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Original base edition only; current law NOT verified. Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. Replaces agreement signed 1985-04-16; exact transitional effects remain unreviewed. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. Replaces agreement signed 1985-04-16; exact transitional effects remain unreviewed. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2012 II S. 526
SHA-256
c33273a0bf5e2ba7148e0fb1303740dab7fa90a37897b100f538c97bbd8a6eb8

Citation

Copyable citation

BGBl. 2012 II S. 526 | de-turkey-2012-base | de-turkey-2012-base | BGBl. 2012 II S. 526 | Signed: 2011-09-19 | Gazette publication: 2012-05-30 | Article 23 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-turkey-2012-base/en/articles/article-23/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 2012 II S. 526

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

Source-page links are references, not human paragraph verification.

Source, edition and limits

Choose agreement