If the foreign company does not have a workplace or a permanent representative in Turkey, the earnings from transportation services are not subject to withholding tax in Turkey. Instead, under the “Double Taxation Avoidance Agreement” between Turkey and Romania, these earnings are taxed only in Romania.
However, if the transportation activity starts and ends within Turkey, withholding tax may apply. If the Romanian company provides a certificate of residency proving that it is a resident of Romania, these earnings will be taxed in Romania and not subject to withholding tax in Turkey.
In summary, for transportation services involving international traffic based in Romania, no withholding tax is paid in Turkey. However, if the service occurs solely within Turkey, a different evaluation may apply.
Source: Revenue Administration
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