Obtaining Tax Treaty Benefits in Turkey– Part 2
Compliance with the Principal Purpose Test (PPT), Limitation on Benefits (LOB), and Other Anti-Abuse Rules Double Taxation Agreements (DTAs) provide significant tax relief for international investors. However, to prevent abuse of treaty benefits, both treaty-level and domestic anti-avoidance provisions have become increasingly strict and central to international tax planning. Following OECD’s BEPS (Base Erosion and […]
Tax Planning for Intangible Property in Turkey
In today’s digitalized world, intangible property has become one of the most valuable assets for businesses. Trademarks, patents, software, copyrights, and trade secrets are not only important for their financial value but also for the competitive advantage they provide. The tax implications of these assets are becoming increasingly critical, especially for companies operating on an […]
Substantive Aspects of Tax Planning in Turkey
Core Elements of Effective and Compliant Tax Strategies Tax planning should not only ensure legal compliance but must also reflect real economic activity, commercial rationale, and the substantive nature of transactions. Today, tax authorities do not rely solely on formal documentation—they also scrutinize whether transactions are based on genuine economic purpose. In this article, we […]
Eligibility to Benefit from Tax Treaties in Turkey
The Double Taxation Avoidance Agreements (DTAs) signed by Turkey provide tax advantages to individuals and entities earning international income. However, in order to benefit from these advantages, certain legal and administrative requirements must be met. This article explains how taxpayers in Turkey can benefit from tax treaties, what documents are required, and what points should […]
Double Taxation Relief in Turkey
Introduction With the rapid growth of global economic activities, it has become increasingly common for individuals and corporations to face taxation on the same income in more than one jurisdiction. This phenomenon—known as double taxation—creates significant challenges for both foreign investors and multinational enterprises. Turkey addresses this issue through an extensive network of Double Taxation […]
The Role and Development of Model Tax Treaties and Commentaries
Double Taxation Avoidance Agreements (DTAAs) are crucial tools in preventing international tax disputes and promoting cross-border economic activity. At the heart of these agreements lie model tax conventions, primarily developed by the OECD and the United Nations (UN), and their accompanying commentaries. These models provide a standardized framework and guide tax treaty negotiations between countries. […]
International Tax Planning
With globalization, it has become increasingly common for individuals and businesses to earn income in more than one country. This reality presents both the risk of double taxation and opportunities for strategic tax planning. International tax planning aims to legally establish the most efficient tax structure within the boundaries of different jurisdictions. 1. What is […]
Introduction to Transfer Pricing: Core Concepts and Turkish Practice
As global business expands and multinational companies grow in complexity, transfer pricing has become one of the most important issues in international taxation. The pricing of intercompany transactions directly affects tax bases, profit allocation, and compliance risks, drawing the close attention of tax authorities around the world — including in Turkey. What Is Transfer Pricing? […]
Dispute Resolution in International Taxation- Mutual Agreement Procedures
One of the most common challenges faced by multinational companies is the risk of double taxation, which arises when two or more countries claim the right to tax the same income. Disagreements between tax authorities—especially on issues such as transfer pricing and permanent establishment—can result in significant tax liabilities. To address such conflicts, Mutual Agreement […]
Tax Treaty Benefits in Turkey: How to Access Double Taxation Relief
In today’s globalized business environment, cross-border transactions and foreign investments are increasingly common. However, such activities can lead to the same income being taxed in both the source and residence countries. To prevent this, countries enter into Double Taxation Avoidance Agreements (DTAAs), which are designed to eliminate or reduce the burden of double taxation. Turkey […]
