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Sayfa XXSayfa 1CHAPTER 1
INTRODUCTION
Tax treaties, by their nature, hold the status of international agreements. The initial…
States enter into agreements for numerous reasons. The most notable among these include…
The tax treaties indicate that states aim to resolve disputes with maximum speed…
The mutual agreement procedure (MAP) is an alternative dispute resolution method…
The “Model Convention,” first accepted by the OECD Council in 1963 as a recommendation…
The “Model Double Taxation Convention Between Developed and Developing Countries,”…
Finally, with Articles 46, 47, 48, 49, and 50 of the Law No. 7338, titled “Law on…
In tax issues involving two or more countries, differences in the interpretation…
When implemented more extensively, the mutual agreement procedure emerges as a method…
The OECD Model Convention and some other agreements provide for arbitration within…
At this point, the focus of this study is on examining, comparing, and analyzing…
In this context, the first chapter of this study provides general information about…
The second chapter addresses tax treaties; the third chapter discusses the method…
LIST OF ABBREVIATIONS
CHAPTER 2 - FUNDAMENTAL PRINCIPLES OF INTERNATIONAL TAXATION AND TAX TREATIES
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