MEMORANDUM OF UNDERSTANDING 

At the signing today of the Agreement Between the Government of the United States of 

~erica and the Government of the Republic of Turkey to Improve International Tax 

Compliance Through Enhanced Exchange of Information (the .. Agreement"), the 

representatives of the United States of America and the Republic of Turkey wish to 

confirm their understanding of the following: ! 

1. It is understood that, in the case of securities registered in the Turkish Central 

Securities Depository (Merkezi Kaytt Kurulu~u Anonim $irketi) as defined in Articles 13, 

80 and 81 ofthe Turkish Capital Market Law of December 6, 2012, nr. 6362 that are held by 

or through one or more other Financial Institutions, the relevant Financial Accounts are to be 

treated as held by such other Financial Institutions, and such other Financial Institutions are to 

be responsible for any reporting required with respect to such Financial Accounts. 

Notwithstanding the foregoing, in accordance with paragraph 3 of Article 5 of the Agreement, 

the Central Securities Depository may report on behalf of such other Financial Institutions. 

2. In reference to paragraph 1 of Article 10 (Term of Agreement), the Government of 

the United States understands that the Government of the Republic of Turkey intends to 

i.ntroduce legislation that is to enable the Agreement to be implemented in Turkey, with 

the goal of having the Agreement enter into force by September 30, 20 I 5. Based on this 

understanding, as of the date of signature of the Agreement, the United States Department 

of the Treasury continues to treat each Turkish Financial Institution, as that term is defined 

in the Agreement, as complying with, and not subject to withholding under, section 1471 

of the U.S. Internal Revenue Code during such time as Turkey is pursuing the necessary 

internal procedures for entry into force of the Agreement. The United States further 

understands that the Turkish Revenue Administration intends to contact the United States 

Department of the Treasury as soon as it is aware that there might be a delay in the 

Turkish internal approval process for entry into force of the Agreement such that Turkey 

would not be able to provide its notification under paragraph 1 of Article 10 of the 

Agreement prior to September 30, 2015. If upon consultation with Turkey, the United 

States Department of the Treasury receives credible assurances that such a delay is likely 

to be resolved in a reasonable period of time, the United States Department of the 

Treasury may decide to continue to apply F ATCA to Turkish Financial Institutions in the 

manner described above as long as the United States Department of the Treasury assesses 

that Turkey is likely to be able to send its notification under paragraph 1 of Article I 0 by 

September 30, 20 16. It is understood that should the Agreement enter into force after 

September 30, 2015, any information that would have been reportable under the 

Agreement thereafter (and prior to its entry into force) had the Agreement been in force by 

September 30, 2015, is owed on the September 30 next following the date of entry into 

force. 
Signed at Ankara, in duplicate, in the English and Turkish languages, both texts being 

equally official, this 29th day of July, 2015. 

FOR THE GOVERNMENT OF 

THE UNITED STATES OF AMERICA 

John R. BASS 

Ambassador 

TOF 

KEY