Highlights of the Treaty Sample Clauses

Highlights of the Treaty. I. Dual-resident companies An individual person or a corporate entity may very well be regarded as being resident in Germany and Turkey, e.g. a corporate entity might have a Turkish registered office but is actually managed from German territory (dual resident company). According to the Treaty, the residence of such company shall be determined for treaty purposes by way of mutual agreement on a case by case approach, i.e. the competent German and Turkish authorities shall endeavor to settle the status of the dual resident company. Contrary to the former treaty, it is explicitly stated in the Treaty that in case the competent authorities do not reach an agreement, the dual resident company will be regarded as resident of neither Germany nor Turkey. This way, it is made clear that a dual resident company, in case the authorities do not reach a mutual agreement, cannot benefit from the Treaty.