1 In the case of Canada, double taxation shall be avoided as follows: 1. In the other Contracting State, nationals of a Contracting State may not be subject to any other taxation or obligation associated with it, or which is different or more onerous than the taxation and related requirements to which nationals of that other State are or may be subject in the same circumstances. 1. If a State established in a Contracting State considers that the acts of one or both Contracting States will result in taxation for that person which is not in conformity with the provisions of this Convention, that person may, irrespective of the remedies provided for by the national law of those States, be addressed to the competent authority of the Contracting State in which that person is established: send a written request stating the reasons for the revision of this taxation. 5. In this Article, “taxation” means the taxes which are the subject of this Convention. Agreement between the Government of the Russian Federation and the Government of the Republic of Albania for the avoidance of double taxation on the basis of income and property At the time of signature of the Agreement between Canada and the Republic of Turkey for the avoidance of double taxation and the prevention of tax evasion on taxes on income and capital, the undersigned have agreed on the following provisions, which form an integral part of the Treaty. 3 For the purposes of applying points (a) and (b) of paragraph 1 to a company established in Canada, the tax payable in Turkey shall include any tax which would have been due in Turkey for profits attributable to an undertaking operating in Turkey in a tax year but for a tax exemption or reduction granted for that year; or parts thereof in the context of special tax measures in Turkey, in so far as those measures were in force on the day of signature of the Agreement and have not been amended or have been slightly modified since then, so as not to alter its general character. This paragraph shall apply to taxes other than those withheld at source for fiscal years beginning on or after the first day of January of the following calendar year. 9.
Of course, nothing in the agreement should be interpreted to prevent Canada from collecting tax on amounts contained in the income of a Canadian-based business in respect of a partnership, trust or controlled foreign subsidiary of interest to that resident. It is also considered that this provision did not rank Canada with respect to the taxation of residents of Turkey. 4. The Agreement shall also apply to substantially similar taxes and capital taxes levied after the date of signature of the Agreement, in addition to or in place of existing taxes. . . .