Income Tax Practices in Turkey for Shares, Partnership Rights, and Withholding Tax
With the development of capital markets in Turkey and the diversification of income types, the taxation of income derived by individuals and legal entities from shares, partnership rights, investment income, interest, and other returns has become increasingly important. The Income Tax Law (ITL) and related legislation regulate the taxation of these incomes through filing, withholding, […]
Attribution of Profits to Permanent Establishments Post-BEPS in Turkey
PE and Profit Attribution in Turkey: Core Concepts Permanent Establishment (PE): A fixed place of business (or dependent agent arrangement) through which a foreign enterprise carries on business in Turkey. Profit attribution: Allocation of an enterprise’s profits to its PE based on the PE’s functions performed, risks assumed, and assets used. Post-BEPS Principles for Profit […]
Tax Treaties in Turkey
Tax treaties in Turkey, also known as double taxation avoidance agreements, are international agreements designed to prevent the same income from being taxed both in the country where it is earned and in the country where the taxpayer is resident. These agreements play a crucial role in encouraging foreign investment, facilitating capital movement, and supporting […]
Legal Framework of Transfer Pricing in Turkey
Transfer pricing plays a vital role in ensuring tax compliance and preventing base erosion in economies integrated into the global market. Turkey has closely followed international developments in this area and incorporated them into its domestic legal system, providing clear rules and obligations for taxpayers. This article outlines the legal basis, key regulations, and international […]
Dispute Resolution in Tax Matters – Part 2: Arbitration in Tax Matters
With the increasing complexity of international trade and multinational operations, tax disputes have become a critical issue for both taxpayers and tax authorities. Issues such as double taxation and transfer pricing frequently lead to disagreements between countries, requiring effective resolution mechanisms. Alongside the Mutual Agreement Procedure (MAP), arbitration has emerged as an essential mechanism that […]
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 […]
