ARTICLE 23

Relief from Double Taxation

1. In accordance with the provisions and subject to the limitations of the law of the United States (as it may be amended from time to time without changing the general principle hereof), the United States shall allow to a resident or citizen of the United States as a credit against the United States tax on income:

a) the tax paid on income to Turkey by or on behalf of such citizen or resident; and b) in the case of a United States company owning at least 10 percent of the voting stock of a company which is a resident of Turkey and from which the United States company receives dividends, the tax paid on income to Turkey by or on behalf of the distributing company with respect to the profits out of which the dividends are paid. For the purposes of this paragraph, the taxes referred to in subparagraph a) of paragraph 2 and paragraph 3 of Article 2 (Taxes Covered) shall be considered income taxes.

2. Where a resident of Turkey derives income which, in accordance with the provisions of this Agreement, may be taxed in the United States and in Turkey, Turkey shall, subject to the provisions of Turkish taxation laws regarding credit for foreign taxes (as they may be amended from time to time without changing the general principles hereof), allow as a deduction from the tax on income of that person, an amount equal to the tax on income paid in the United States. 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 the United States.

3. For the purposes of allowing relief from double taxation pursuant to this Article, and subject to such source rules in the domestic laws of the Contracting State as apply for the purpose of limiting the foreign tax credit, income derived by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Agreement (other than solely by reason of citizenship in

accordance with paragraph 3 of Article 1 (Personal Scope)) shall be deemed to arise in that other State. The rules of this paragraph shall not apply in determining credits against United States tax for foreign taxes other than the taxes referred to in subparagraph a) of paragraph 2 and paragraph 3 of Article 2 (Taxes Covered).