Süleyman Hayri BALCI. Head of Group Presidency of Revenue Administration Ministry of Finance

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1 Süleyman Hayri BALCI Head of Group Presidency of Revenue Administration Ministry of Finance

2 AVOIDANCE OF DOUBLE TAXATION

3 In the era of globalization, the international mobility of capital, technology and persons; the geographical dispersion of firms and their increasing contacts and dealings with other countries have clear advantages for growth and modernization of the countries.

4 However, functional, organizational and economic complexities of the modern trade and business give rise to the double taxation problem, thus cross-border efforts to remove obstacles stemmed from it.

5 Within this context, tax treaties have started to play a considerably key role to prevent excessive or inappropriate tax practices caused by double taxation and ensure fairer, safer and more efficient tax treatments. According to the OECD data as of 2010, there are more than 3000 tax treaties worldwide.

6 So, let s look through what double taxation is; Double taxation occurs when one and the same taxable income is subject to taxation in two or more states, for one and the same time period. We can mention about two types of double taxation: Juridical double taxation and economic double taxation.

7 Juridical Double Taxation International juridical double taxation is imposition of income taxes in two (or more) states on the same taxpayer regarding the same income.

8 Economic Double Taxation Economic double taxation occurs if more than one state s tax administration include the same income in the tax base when the income is in the hands of different taxpayers.

9 Harmful Effects of Double Taxation increases burden of tax on foreign income, negatively affects cross-border movements of investments, expertise and technology, distorts the efficient allocation of scarce financial resources,

10 Harmful Effects of Double Taxation adversely affects economic growth of developing countries, makes market competition difficult, increases tax evasion, leads to tax discrimination.

11 Avoidance of Double Taxation Avoidance of double taxation is giving taxation right to a single country or distributing that right between the countries. Legal means of avoidance of double taxation on international scale are double taxation agreements (DTA s).

12 Tax Agreements Objectives to prevent tax evasion, to remove tax related obstacles from international trade and investment by; - providing certainty in tax treatment, - reducing tax rates, - removing tax discrimination, - resolving tax related disputes, - avoiding double taxation.

13 How do tax agreements achieve Tax agreements: these objectives? 1. Eliminate the most common forms of juridical and economic double taxation. 2. Eliminate or reduce some taxes that would otherwise be payable by foreign investors. 3. Eliminate some forms of tax discrimination. 4. Provide a standardized set of rules for dividing tax revenues between countries.

14 How do tax agreements achieve these objectives? 5. Address tax avoidance and evasion. 6. Provide a framework for resolving tax disputes. 7. Provide a stable tax environment to foreign investors (lower compliance costs). 8. Increase the international competitiveness of the economy.

15 Types of Double Taxation Agreements Limited Agreements: These agreements contain certain incomes. For example: Agreements on profits derived from air transport. Comprehensive Agreements: These agreements contain all types of incomes. Turkey s agreements are generally comprehensive.

16 Model Conventions There are two model conventions on which DTA s are based: Organization for Economic Co-operation and Development (OECD) Model Double Taxation Convention and United Nations (UN) Model Double Taxation Convention. All countries benefit from these two models and accept them as guidance for tax practices.

17 Model Conventions OECD MODEL: - residency principle - country of residence of taxpayer has right to tax - generally followed by developed countries - last update: 2010

18 Model Conventions UN MODEL: - source principle - country of source of income has prior right to tax - usually preferred by developing countries - last update: 2011

19 Countries Approach Each country develops its own model compatible with its economic, commercial, social and legal structure, tax system, politics and interests.

20 The Impacts of Model Conventions constituted and developed by participations and contributions of member countries experts and business world, not binding, but a reliable reference source (countries can enter reservations on Article provisions commentaries in the OECD Model),

21 The Impacts of Model Conventions revised upon needs and developments in economics, trade and technology, enable sharing of best practices between the countries revenue administrations,

22 The Impacts of Model Conventions harmonize tax definitions, define taxable bases, indicate the mechanisms to be used to remove double taxation when it arises,

23 The Impacts of Model Conventions facilitate bilateral DTA negotiations, harmonize bilateral agreements, facilitate the interpretation and enforcement of bilateral agreements,

24 The Impacts of Model Conventions include useful commentaries in deciding day to day questions of detail, accelerate administrative decision making process,

25 The Impacts of Model Conventions extensively used by taxpayers when conducting and planning their business transactions and investments, receive judicial attention (courts cite to the models and commentaries).

26 Turkey s Experience Turkey, as a member of the OECD, resorts to the OECD Model in its DTA s. However, there are some differences from the Model in specific issues. Turkey has DTA s with 10 members of BSEC in force (Azerbaijan, Georgia, Moldova, Russian Federation, Ukraine, Bulgaria, Romania, Albania, Serbia and Greece). Turkey signed DTA s with 82 countries and 77 of these agreements are in force.

27 Without international cooperation and coordination, double taxation cannot be avoided. Within this context, regional international organizations make positive contributions to these efforts.

28 Thank you

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