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 […]
Formal Aspects of Tax Planning in Turkey
Effective tax planning at both international and local levels is not only a strategic choice but also a matter of compliance with legal and formal requirements. In Turkey, tax planning practices must be implemented within the framework of the Revenue Administration (GIB) regulations and in line with international standards. This article explores the formal aspects […]
Tax Structuring of Manufacturing and Distribution Activities in Turkey
Strategic Tax Planning for Efficient and Compliant Operations Manufacturing and distribution are central components of the value chain. How these functions are organized and structured not only affects operational efficiency but also significantly influences a company’s tax exposure. For multinational groups and local firms operating in Turkey, effective tax structuring can lead to both cost […]
Formal Aspects of Tax Planning in Turkey
Effective tax planning at both international and local levels must be carried out not only strategically but also in full legal compliance. In Turkey, tax planning practices are implemented within the framework of rules set by the Revenue Administration and in accordance with international standards. In this article, we discuss the formal (legal and procedural) […]
Key Differences Between OECD and UN Model Tax Conventions in Turkey
1. Taxation Principle: Residence vs. Source 2. Definition of Permanent Establishment (PE) 3. Dividends, Interest, and Royalties (Investment Income) 4. Capital Gains 5. Fees for Services and Technical Payments 6. Anti-Abuse Mechanisms 7. Dispute Resolution: MAP and Arbitration Relevance for Turkey: Which Model Is Applied? Turkey, as an active member of the OECD, negotiates most […]
Alternative Tax Initiatives in Turkey: Evolving Framework and Business Implications
Alternative Tax Initiatives in Turkey have emerged as a significant response to the evolving challenges in global taxation. In recent years, both developed and developing economies have sought new frameworks to improve tax compliance, transparency, and fairness. These initiatives complement or sometimes provide alternatives to conventional bilateral tax treaties, especially in the post-BEPS era where […]
International Tax Context in Türkiye: Background and Practical Insights
Understanding the international tax context in Türkiye requires a clear grasp of both the legal framework and the economic background. In areas such as transfer pricing, digital economy taxation, and permanent establishment (PE) rules, it is essential to align international standards with local practices. This article outlines the global framework, Türkiye’s position, and practical challenges […]
ITUS-Based VAT Refund Conditions in Turkey
Taxpayers holding an ITUS Certificate under the Reduced Guarantee Application System may benefit from accelerated VAT refunds in Turkey in line with Article 84 of the Turkish VAT General Communiqué.The framework outlined below reflects the current ITUS-based VAT refund practice applied in 2026, including applicable thresholds, guarantee rates, and refund timelines. 1. Standard ITUS Guarantee […]
The Process of Tax Treaty Negotiations and International Alignment in Turkey
Tax treaties are bilateral agreements established between countries to facilitate economic cooperation, eliminate double taxation, and provide a predictable tax framework for international investment. The preparation of these agreements involves a highly technical, multilateral, and carefully negotiated process. As a member of the OECD and a developing, capital-importing economy, Turkey follows an active and strategic […]
