AGREEMENT between THE GOVERNMENTS

OF HASHMITE KINGDOM OF JORDAN AND

THE REPUBLIC OF TURKEY FOR THE

avoidance OF DOUBLE TAXATION AND

FOR THE ARRANGEMENT OF SOME OTHER

MATTERS WITH RESPECT TO TAXES ON

INCOME AND CAPITAL

THE GWVERNMENTS OF

THE HASHEMITE KINGDOM OF JORDAN

AND

THE REPUBLIC OF TURKEY

Desiring to conclude an agreement for the avoidance of Double taxation and for the arrangement of some other matters with respect to taxes on income and capital

HAVE AGREED AS FOLLOWS:

Article 1

 PERSONAL SCOPE

 This Agreement shall apply to persons who are residents of one or both of the Contracting States.

Article 2

 TAXES COVERED

 1.           This Agreement shall apply to taxes on income and on capital imposed on behalf of each Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

2.            There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienatio of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.  

3.           The existing taxes to which the Agreement shall apply are, in particular:

a)      In the case of Jordan:

aa) Income tax,

bb) Social service Tax applied on the basis of Income Tax;

 b) In the case of Turkey:

 aa) Income tax,

bb) Corporation tax.

4.           The Agreement shall also apply to any identical or substantially similar taxes which are subsequently imposed in addition to, or in place of, the existing taxes. The competent authorities of the contracting States shall notify to each other any changes which have been made in their respective taxation laws.

 Article 3

 GENERAL DEFINITIONS

 1. In this Agreement, unless the context otherwise requires:

 A) The term ''Turkey'' means the territory of the republic of Turkey, including any area in which the laws of Turkey are in force, as well as the continental shelf over which Turkey has in accordance with international law, sovereign rights to explore and exploit its natural resource. The term "Jordan" means the Territory of the Hashemite Kingdom of Jordan, including any area in which the laws of Jordan are in force, as well as the continental shelf over which Jordan has in accordance with International law, sovereign rights to explore and exploit its natural resources.

B) The term "A Contracting State" and " The other Contracting State" mean the Republic of Turkey or the Hashemite kingdom of Jordan as the context requires.

C) The term "Tax" means any Turkish tax of Jordanian Tax covered by Article 2 of this Agreement as the context requires.

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 "Registered office" means the legal head office registered under the Turkish Code of commerce or the legal head office registered under Jordanian Companies law.

G) The term ''Nationals'' means:

 aa) In respect of the Republic of Turkey, all individuals pos-sassing the Turkish nationality under the "Turkish Nationality Code" and all legal persons, partnerships and associations deriving their status as such from the law in force in the Republic of Turkey.                                                                                             

bb) In respect of the Hashemite Kingdom of Johann, all in-dividuals possessing the Jordanian nationality under the ''Jordanian Nationality Code" and all legal persons, partnerships and associations deriving their status as such from the law in force in the Hashemite Kingdom of Jordan.

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;

aa) In Jordan the Minister of finance.

bb) In Turkey, the Minister of Finance and Customs.

 2. As regards the application of this Agreement by a Contracting State any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of this Agreement.

 Article 4

 Fiscal DOMICILE

1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the law of that State, is liable to taxation therein, by reason of his domicile, residence, legal head office  (Registered Office ), place of management or any criterion of a similar nature.

2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then this case shall be determined in accordance with the following rules.

A) He shall be deemed to be a resident of the Contracting state in which he has a permanent home available to him.

If he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer (Centre of vital interests).

B) If the Contracting State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either contracting State, he shall be deemed to be a resident of the Contracting State in which he has ah habitual abode.

C) If he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident of the Contracting State or which he is a national.

d) If he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement

3. Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States then it shall be deemed to be resident of the Contracting State in which its registered office is situated. 

Article 5

 PERMANENT ESTABLISHMENT

 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

2. The term "permanent establishment" includes especially:

A) A place of management.

B) A branch.

C) An office.

D) A factory.

E) A workshop, and

F) A mine, an oil or gas well, a quarry or any other place of extraction of natural resources.

3. A building site or construction or installation project constitutes a permanent establishment only if it lasts more than six months.  

4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include.

A) The use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise.

C) The maintenance of a stock of goods or merchandise belonging to the  enterprise solely for the purpose of processing by another enterprise.

D) The maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise.

E) The maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise: any other activity of a preparatory or auxillary character.

F) The maintenance of a fixed place of business solely for any Combination of activities mentioned in sub-paragraphs a) to e) , provided that the overall activity of the fixed place of business resulting from this combination of a preparatory or auxiliary character.

5) Notwithstanding the provisions of paragraphs 1 and 2, while a person-other than an agent of an independent status to whom paragraph 6 applies-is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that state in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph.

6) An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that state through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.

7. The fact that a company which is a resident of a Contracting state controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State ( whether through a permanent establishment or otherwise), shall not of itself constitute a permanent establishment for the other.

Article 6

INCOME  FROM  IMMOVABLE  PROPERTY

1. Income from immovable property ( including income from agriculture or forestry) may be taxed in the contracting State in which such property is situated.

2. The term "immovable property" shall be defined in accordance with the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry fishing places of every kind, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources, and other natural resources, ships, boats and aircraft shall not be regarded as immovable property.

3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property.

4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent services.

Article 7

business profits

 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.

If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment.

2. Subject to the provisions of paragraph 3, where an enterprise of a contracting State carries on business in the other Contraction State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make i it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.

3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.

4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchardise for the enterprise.

5. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

Article 8

SHIPPING AIR AND LAND TRANSPORT

 1. Profits of an enterprise of a Contracting State derived from the other contracting State from the operation of ships, aircraft or road vehicles in international traffic may be taxed in the first mentioned State.

2. The expression "International traffic" means any transport by a ship or an aircraft or a road vehicle by a Turkish or a Jordanian enterprise except when the ship or the aircraft or the road Vehicle is operated solely between places situated in territory of Turkey or of Jordan.

Article 9

INTERDEPENDENT ENTERPRISES

1.  Where

a) an enterprise of a Contracting State participates directly or indirectly in the management, control or financing of an enterprise of the other contracting State, or

b) the same persons participate directly or indirectly in the management, control or financing of an enterprise of a Contracting State and an enterprise of the other Contracting

State, 

and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for these conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

2. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first - mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this agreement and the competent authorities of the Contracting States shall if necessary consult each other.

Article 10

DIVIDENDS

1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other state.

2. However, such dividends may be taxed in the Contracting State of which the company paying the dividends is a resident, and according to the law of that state; but the tax so charged shall not exceed:

A) 10 per cent of the gross amount of the dividends if the recipient is a company (excluding partner-ship) which holds directly at least 25 per cent of the capital of the company paying the dividends.

B) In all other cases, 15 per cent of the gross amount of the dividends.

3. The term "dividends" as used in this Article means income from shares "Jouissance'' shares or ''Jouissance'' rights, founders shares or other rights, not being debtclaims participating in profits, as well as income from other corporate rights assimilated to income from shares by the taxation law of the State of which the company making the distribution is a resident, and income derived from an investment fund and investment trust.

4. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the dividends, being a resident of a Contracting State, has in the other Contracting State of which the company paying the dividends is a resident, a pertinent establishment with which the holding   by virtue of which the dividends are paid is effectively In such a case, the provisions of Article 7 shall apply.

Article 11

INTEREST

 1. Interest arising in a contracting State and paid to a resident of the other contracting State may be taxed in that other State.

2. However, Such interest may be taxed in the contracting State in which it arises, and according to the law of that State, but the Tax so charged shall not exceed, 10 per cent of the amount of the interest.

3. Notwithstanding the provisions of paragraph 2, interest arising in :

a) Jordan and paid to the Government of Turkey or to the Central Bank of Turkey (Turkiye Cumhuriyetl Merkez Bankasi) shall be exempt from Jordanian tax.

b) Turkey and paid to the Government of Jordan or to the Central Bank of Jordan shall be exempt from Turkish tax.

4. The term "interest" as used in this Article means income from Government securities, bonds or debentures, whether or not secured by mortgage and whether or not carrying a right to participate in profits, and debt claims of every kind as well as all other income assimilated to income from money lent by the taxation law of the State in which the income arises.

5. The provisions or paragraphs 1 and 2 shall not apply if the recipient of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, and the debt claim in respect of which the interest is paid is effectively connected with such permanent establishment in such cases, the provisions of Article 7 shall apply.

6. Interest shall be deemed to arise in a contracting State when the payer is that State it self, a political subdivision, a local authority or a resident of that State where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

7. Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the interest paid having regard to the debt claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last mentioned amount. In that  Case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the provisions of this Agreement.

Article 12

ROYALTIES

 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2. However, such royalties may be taxed in the Contracting State in which they arise, and according to the law of that State, but the tax so charged shall not exceed 12 per cent of the gross amount of the royalties.

3. The term ''Royalties'' as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and television, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial. or scientific equipment, or for information concerning, industrial, commercial or scientific experience.

4. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the royalties, being a resident of a Contracting State, has in the other Contracting State in which the royalties arise a permanent establishment with which the right or property giving rise to the royalties is effectively connected. In such a case, the provisions of Article 7 shall apply.

5. Royalties shall be deemed to arise in a Contracting state when the payer is that State itself, a political subdivision, a local authority or a resident of that State, where, however, the person paying the royalties, whether he is a resident of a contracting State or not, has in a Contracting State a permanent establishment with which the right or property giving rise to the royalties is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

6. Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, havins regard to the use, right or information   for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable accorting to the law of each Contracting State, due regard being had to the other provisions of this Agreement.

Article 13

CAPITAL GINS

  1. Gains from the alienation of immovable property, as defined in paragraph 2 of Article 6, may be taxed in the Contracting State in which such property is situated.

2. Gains from the alienation of movable property forming part of the business property of a permanent establishment with an enterprise of a contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a contracting State in the other Contracting State for the purpose of performing professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base, may be taxed in the other State.

3. However, gains from the alienation of movable property of the kind referred to in paragraph 3 of Article 22 shall be taxable only in the Contracting State, in which such movable property is taxable according to the said Article.

4. Gains from the alienation of any property other than those mentioned in paragraphs 1,2 and 3 shall be taxable only in the State of which the alienator is a resident. However, the capital gains mentioned in the foregoing sentence and derived from the other Contracting State, shall be taxable in the other Contracting State if the time period does not exceed one year between acquisition and alienation.

Article 14

INDEPENDENT personal SERVICES

1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an indecent character shall be taxable only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other State but only so much of it as is attributable to that Taxed base.

2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

Article 15

DEPENDENT personal services

 1. Subject to the provisions of Articles 16, 17, 18, 19 and 20, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State . If the employment is so exercised, such remuneration as is derived there from may be taxed in that other State.

2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first mentioned State if: a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned, and  

b. the remuneration is paid by, or on behalf of an employer who is not a resident of the other State, and

c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.

3. Notwithstanding the provisions of paragraphs 1 and 2, remunerations in respect of an employment exercised aboard a ship or aircraft or road vehicle in international traffic may be taxed in the Contracting State in which the registered office of the enterprise is situated.

Article 16

DIRECTORS FEES

   Directors' fees and similar payments derived by a resident of a contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State.

article 17

artistes AND ATHLETES

 1. Notwithstanding the provisions of Articles 14 and 15, income derived by public entertainers, such as theatre, motion picture, radio or television artistes, and musicians, and by athletes, from their independent activities as such may be taxed in the Contracting State in which these activities are exercised.

2. Where income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of articles 7, 14 and 15 be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.

Article 18

PENSIONS

 Subject to the provisions of paragraph 1 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.

Article 19

GOVERMENTAL FUNCTIONS

   1. Remuneration, including pensions, paid by, or out of funds created by, a Contracting State or political subdivision or a local authority thereof to any individual in respect of services rendered to that State or political subdivision or local authority thereof in the discharge of functions of a governmental nature may be taxed in that State.

2. The provisions of Articles 15, 16 and 18 shall apply to remuneration or pensions in respect of services rendered in connection with any trade or business carried on by one of the Contracting State or a political subdivision or a local authority thereof.

Article 20

TEACHERS AND STUDENTS

 1. Payments which a student or business apprentice who is a national of a Contracting State and who resides temporarily in the other Contracting State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that other State, provided that such payments are made to him from sources outside that other State.

2. Likewise, remuneration received by a teacher or by an instructor who is a national of a Contracting State and who resides temporarily in the other Contracting State and the primary purpose of teaching orengeging in scientific research for a period or periods not exceeding two years shall be exempt from tax in that other State on his   remunerations from personal services for teaching or research, provided that such payments are received from sources outside that other State.

3. Remuneration which a student or a trainee who is a national of a Contracting State derives from an employment which he exercises in the other Contracting State for a period or periods not exceeding 183 days in a calendar year, in order to obtain practical experience related to his education or formation shall not be taxed in that other State.

Article 21

OTHER income

 1. Items of income of a resident of a Contracting State, wherever arising, not dealt within the foregoing articles of this Agreement shall be taxable only in that state.

2. Items of income arising outside the two Contracting States shall be taxable only in the Contracting State of which the person receiving the income in question is a resident.

 Article 22

CAPITAL

1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, may be taxed in the Contracting State in which such property is situated.

2. Capital represented by movable property forming part of the business property of a permanent establishment of an enterprise, or by movable property pertaining to a fixed base used for the performance of independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated.

3. Ships or aircraft or road vehicle operated in inter - national traffic by an enterprise of a Contracting State and movable property pertaining to the operation of such ships and aircraft and road vehicles shall be taxable only in the contracting State in which the registered office of the enterprise in situated.

4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Article 23

METHODS OF ELIMINATION

 1.                   Where a resident of Turkey derives income or owns capital which in accordance with the provisions of this Agreement, may be taxed in Jordan, Turkey shall allow as a deduction from the tax on the income or capital of that person, an amount equal to the tax paid in Jordan.

Such deduction shall not, however, exceed that part of the tax computed before the deduction is given, which is appropriate to the income or capital which may be taxed in Jordan.

2. Taxes paid in Turkey by Jordanian residents on income derived or capital on in accordance with the provisions of this Agreement, may be taxed in Turkey, shall be deducted from the Tax on such income or capital for the purpose of taxing them in Jordan.

Article 24

NON-DISCRIMINATION

   1. The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected there with which is other or more burden so me than the taxation and connected requirements to which nationals of that other State in the same circumstance are or may be subjected.

2. The taxation on a permanent establishment which an enterprise of a Contracting state, has in the other Contracting State shall not be less favorably levied in that other   State than the taxation levied on enterprises of that other State carrying on the same activities.

3. 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 Contracting state to any taxation or any requirement connected there with which is other or more burdensome then the taxation and connected requirements to which other similar enterprises of that first-mentioned State are or may be subjected.

4. Provisions of this Article shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, relief's and reduction for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

Article 25

exchange OF INFORMATION

1.A) The competent authorities of the Contracting States shall exchange such information as is necessary for the carrying out of this Agreement and of the domestic laws of the Contracting States concerning taxes covered by this Agreement insofar as the taxation there under is in accordance with this Agreement.

B) Any information so exchanged shall be treated as secret and shall not be disclosed to any person or authorities other than those concerned with the assessment or collection of the taxes which are the subject of the Agreement and with related complaints and resources as well as Judiciary authorities for penal prosecutions related with the above mentioned taxes.

2. In no case shall the provisions of paragraph 1 be construed so as to impose on one of the Contracting States the obligation:

A) To carry out administrative measures at variance with the laws or the administrative practice of that or of the other Contracting State.

B) To supply particulars which are not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State.

C) To supply information which would disclose any trade, business. industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy.

Article 26

administrative assistance

1. The Contracting States engage to provide aid and assistance mutually for the purpose of notification and collection of principal, increments, additions, interests, expenses and fines without penal character, taxes covered by the Article 2.

2. On the request of the competent authority of a Contracting State, the competent authority of the other Contracting State will ensure according to the provisions of laws and regulations applied to notification and collection of the above mentioned taxes in the last State, notification and collection of fiscal claims covered by the first paragraph, which are recoverable in the first State. These claims shall not enjoy any privilege in the requested State and the latter is not obliged to apply means of execution which are not authorized by the provisions of laws and regulations of the requesting State.

3. Requests covered by paragraph 2, shall be supported by an official copy of executory documents, accompanied, when needed by an official copy of judgments.

4. With respect to fiscal claims susceptible to appeal, the competent authority of a Contracting State could, for the safeguard of its rights, request the competent authority of the other Contracting State, to take measures of conservation as prescribed in the legislation of the latter State, provisions of paragraphs 1 to 3 could be applied, also, to these measures,

5. Article 25, paragraph 1, sub - paragraph b, shall apply equally to all information brought, for the application of preceding paragraphs of the present Article, to the knowledge of the competent authority or the requested State.

Article 27

mutual agreement PROCEDURE

1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Agreement, he may, not with standing the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

2. The competent authority shall endeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the Agreement.

3. The competent authorities of the contracting States shall endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement.

4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an. agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a commission consisting of representatives of the competent authorities of the Contracting States.

Article 28

DIPLOMATIC AND CONSULAR OFFICIALS

Nothing in this Agreement shall affect the fiscal privileges of diplomatic or consular officials under the general rules of international law or under the provisions of special agreements.

Article 29

ENTRY INTo FORCE

1. This agreement shall be ratified and the instruments of ratification shall be exchanged as soon as possible.

2. The Agreement shall enter into force upon the exchange of instruments of ratification and its provisions shall have effect:

A) In Turkey, for taxes with respect to every taxable year beginning on or after the first day of January of the year following that of entry into force of the agreement.

B) In Jordan, for taxes with respect to every taxable year beginning on or after the first day of January of the year following that of entry into force of the Agreement.

Article 30

TERMINATION

This Agreement shall remain in force until denounced by one of the Contracting States. Either Contracting State may denounce the Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year.

In such event, the Agreement shall cease to have effect:

A) In Turkey, for taxes with respect to every taxable year beginning on or after the first day of January of the year following that in which the notice of termination is given.

B) In Jordan, for taxes with respect to every taxable year beginning on or after the first day of January of the year following that in which the notice of termination is given.

In witness whereof, the undersigned plenipotentiaries have signed the present agreement and have affixed their seals thereto.

Done at                                         Amman                                       on 6 th . June 1985

In duplicate, in the Arabic. Turkish. and English Languages, all three texts being authentic. In case of any divergent interpretations of the Arabic and Turkish texts, the English text shall prevail.

FOR THE HASHEMITE KINGDOM OF                                        FOR THE   REPUBLIC OF

JORDAN                                                        TURKEY

H. E . Mr . Salmon Al-Tarwneh                                                  H.E Mr. Resat Arim

Director Genteral Of                                                    Ambassador of the Republic

Income Tax Department / Ministry                                                Of Turkey in Amman -

of Finance