The profits of the special joint venture which is deemed to be a corporate body under the Turkish Corporation Tax Act shall be taxable only in Turkey. However if the activities of such a joint venture do not fulfill the requirements of the provisions of paragraph 3 of Article 5, then for the purposes of this Agreement the corporate body status of that joint venture shall not be taken into account and the Netherlands enterprise who is a partner in such a joint venture shall not be taxable in Turkey for its share in the profits of the joint venture and also for the deemed dividend paid by such joint venture to the Netherlands enterprise.
