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 independent character shall be taxable only in that Contracting State. However, such income may also be taxed in that other Contracting State if such services or activities are performed in that other Contracting State and if: 　　(a) he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; or 　　(b) his stay in the other Contracting State for the purpose of performing his activities for a period or periods exceeding in the aggregate 183 days in the calendar year concerned. 　　In such circumstances, only so of the income as is attributable to that fixed base or is derived from the services or activities performed during his presence in that other Contracting State, as the case may be, may be taxed in that other Contracting State. 　　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, 18, 19, 20 and 21, 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting 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 Contracting 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 Contracting State; and 　　(c) the remuneration is not borne by a paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship, aircraft or land vehicle operated in international traffic by an enterprise of a Contracting State shall be taxable only in that Contracting State. 　　Article 16 Directors' Fees 　　Directors' fees and other 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 Contracting State. 　　Article 17 Artistes and Athletes 　　1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed in that other Contracting State. 　　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. 　　3. Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainers or athletes who are residents of a Contracting State from the activities exercised in the other Contracting State under the cultural exchange programmes between the Governments of the both Contracting State shall be exempt from tax in that other Contracting State. 　　Article 18 Pensions 　　1. Subject to the provisions of paragraph 2 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 Contracting State. 　　2. Notwithstanding the provisions of paragraph 1, pensions paid and other similar payments made by the Government of a Contracting State or a political subdivision or a local authority thereof under other social security system of that Contracting State shall be taxable only in that Contracting State. 　　Article 19 Government Service 　　1. (a) Remuneration, other than a pension, paid by the Government of a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or a political subdivision or a local authority thereof , in the discharge of functions of a governmental mature, shall be taxable only in that Contracting State. 　　(c) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other Contracting State who: 　　(i) is a national of that other Contracting State; or 　　(ii) did not become a resident of that other Contracting State solely for the purpose of rendering the services. 　　2. (a) Any pension paid by, or out of funds to which contributions are made by , the Government of a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or a political subdivision or a local authority thereof shall be taxable only in that Contracting State. 　　(b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of , that other Contracting State. 　　3. The provisions of Articles 15, 16, 17, and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by the Government of a Contracting State or a political subdivision or a local authority thereof. 　　Article 20 Students and Trainees 　　A student, business apprentice or trainee who is or was immediately before visiting a Contracting State a resident of the Contracting State and who is present in the first-mentioned Contracting State solely for the purpose of his education or training shall be exempt from tax in that first-mentioned State on the following payments or income received or derived by him form the purpose of his maintenance, education or training: 　　(a) income derived from sources outside that Contracting State for the purpose of his maintenance, education , study, research or training; 　　(b) grants, scholarships or awards supplied by the Government of the first-mentioned Contracting State or a scientific, educational, cultural or other tax-exempt organization; and 　　(c) income derived from an employment which exercised in the first-mentioned 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 for formation. Article 21 Teachers and Researchers 　　Remuneration received by a teacher or by an instructor who is a national of a Contracting State and who is present in the other Contracting Stated and the primary purpose of teaching or engaging in scientific research for a period or periods not exceeding two years shall be exempt form tax in that other State on his remuneration from personal services from teaching or research, provided that such payments arise from sources outside that other Contracting State. 　　　Article 22 other Income 　　1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that Contracting State. 　　2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case, such income shall be taxed according to the provisions of tax laws of that other Contracting State. 　　Article 23 Elimination of Double Taxation 　　1. Double taxation for the residents of Turkey shall be eliminated as follows: Where a resident of Turkey derives income which, in accordance with the provisions of this Agreement, may be taxed in China and in Turkey, Turkey shall , subject to the provisions of Turkish taxation laws regarding credit for foreign taxes, allow as a deduction form the tax on income of that person, and amount equal to the tax on income paid in China. Such deduction shall not, however, exceed that part of the income tax computed in Turkey before the deduction is given, which is appropriate to the income which may be taxed in China. 　　2. Double taxation for the residents of China shall be eliminated as follows: 　　(a) Where a resident of China derives income from Turkey the amount of tax that income payable on Turkey in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of credit ,however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation laws and regulation of China. 　　(b) Where the income derived from Turkey is a dividend paid by a company which is a resident of Turkey to a company which is a resident of China and which owns not less than 10 per cent of the chares of the company paying the dividend ,the credit shall take into account the tax paid to Turkey by the company paying the dividend in respect of its income. 　　Article 24 Non-discrimination 　　1. Nationals of a Contracting State shall not be subject 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 Contracting State in the same circumstances are 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 favourably levied in that other Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. 　　3. Except where the provisions of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursement 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. 　　4. 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 burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.　 　　5. These provisions shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. 　　Article 25 Mutual Agreement Procedure 　　1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is national. The case must be presented within one year from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement. 　　2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory 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 which is not in accordance with this Agreement. Any agreement reached shall be implemented within one year and the beneficiary of exemption or reduction shall enjoy this right within a maximum period of one year as of the notification of this decision on tax exemption or reduction. 　　3. The competent authorities of the Contracting State shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 for the purpose of reching agreement, representatives of the competent authorities of the Contracting State may meet together for an oral exchange of opinions. 　　Article 26 Exchange of Information 　　1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement, insofar as the taxation thereunder is not contrary to this Agreement, in particular for the prevention of evasion of such taxes. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that Contracting State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of or the determination of appeals in relation to , the taxes covered by the Agreement. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 2. In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: 　　(a) to carry out administrative measures at variance with the law and administrative practice of that or of the other Contracting State; 　 (b) to supply information which is 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 (ordre public). Article 27 Diplomatic Agents and Consular officers Nothing in this Agreement shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements. 　　Article 28 Entry into Force 　　1. The Government of the Contracting States shall notify each other the completion of the internal legal procedures necessary for the bringing into force of this Agreement. 　　2. This Agreement shall enter into force on the date on which the latter of the notifications has been received. Its provisions shall have effect in respect of taxes for the taxable year beginning on or after the first day of January in the calendar year next following that in which this Agreement enters into force and 5ubsequent taxable years. 　 Article 29 Termination 　This Agreement shall continue in effect indefinitely; but, either of the Contracting States may, on or before the thirtieth day of June in any calendar year beginning after the Expiration of a period of five years from the date of its entry into force, give written notice of termination to the other Contracting State though the diplomatic channels. In such event, this Agreement shall cease to have effect in respect of taxes for the taxable year beginning on or after the first day of January in the calendar year next following that in which the notice of termination is given and subsequent taxable years. 　　In witness whereof, the undersigned, duly authorized there to by their respective Governments, have signed this Agreement. Done in duplicate at Beijing this 23 rd day of May 1995 in the Chinese, Turkish, and English Languages, all three texts being equally authentic. In case of divergence in interpretation the English text shall prevail. For the Government of the People's For the Government of Republic of China the Republic of Turkey