Abstract
This article examines corporate taxation in Turkey from the perspective of foreign-owned subsidiaries, joint ventures and branches. It distinguishes tax residence, taxable profit, corporate income tax, domestic minimum tax, multinational top-up tax, VAT and withholding on cross-border payments. It also considers related-party financing, transaction taxes, filing obligations and the procedural safeguards relevant to a tax dispute. Particular attention is given to changes already applicable in 2026 and the production-rate amendment scheduled for 2027. The analysis argues that an investment model should follow the actual entity, activity, payment flow and accounting period rather than a single headline rate. Reliable advice requires coordination between legal and accounting professionals, evidence supporting treaty and deduction claims, and a practical plan for preserving challenge rights when an assessment is disputed.
Introduction
A Turkish operation can show a 25% corporate tax charge and still require a materially different cash budget. VAT may be carried forward instead of refunded, a payment to the foreign parent may attract withholding, and a contract may trigger stamp tax. Those costs arise under different rules and cannot safely be modelled as a single percentage of profit.
The useful starting point is a map of the business: the legal entity, where it is managed, what it sells, where services are used, how it is financed and how money will leave Turkey. This article addresses those questions for ordinary commercial businesses. Financial institutions, incentive beneficiaries and large multinational groups require additional analysis. The review date is 21 September 2026; future commencement dates are stated separately.
1. Tax residence, subsidiaries and permanent establishments
Article 3 of Corporate Tax Law No. 5520 treats a company with its legal centre or business centre in Turkey as fully taxable on worldwide earnings. Where both centres are abroad, liability is limited to Turkish-source earnings. A Turkish subsidiary does not become non-resident merely because its shareholders or ultimate parent are foreign.1
For a foreign enterprise, a branch or permanent establishment can create a Turkish business-profit exposure. It is not, however, the only possible source of Turkish tax: income such as royalties, interest or rent may be taxable under separate source and withholding rules even without a branch. An applicable treaty may restrict the domestic taxing right. A registered branch, a treaty permanent establishment and a subsidiary are therefore different legal categories.2
Before choosing a structure, reconcile the proposed contracts with the actual activity. Who negotiates and signs sales? Where do personnel work? Who bears inventory risk? Where is the service used? A foreign address on an invoice does not resolve those questions, and incorporating a subsidiary does not automatically isolate every activity of the parent from Turkish tax review.
2. Corporate income tax: rates, the base and minimum taxation
The current headline rates
The ordinary corporate income tax rate is 25%. The statutory 30% category includes specified financial institutions and companies within the prescribed build-operate-transfer and health public-private partnership regimes. Foreign ownership itself is not a reason for the higher rate. Law No. 7456 introduced the 2023 rate increase; later changes must be read by taxpayer category and accounting period.3
Taxable profit is not necessarily the profit reported in the parent’s consolidated accounts. The computation must reconcile accounting income with non-deductible expenses, exemptions, loss relief and permitted deductions. A payment supported by an invoice may still fail a substantive deductibility test. Conversely, a lawful relief should not be abandoned merely because the group’s reporting template does not contain a line for it.4
Two minimum-tax regimes must not be confused
Domestic minimum corporate tax under Article 32/C generally applies from the 2025 accounting period. It compares ordinary corporate tax with a 10% floor calculated on the statutory adjusted base, subject to specified exclusions and adjustments. It is not a 10% turnover tax and is not simply ten percentage points added to the ordinary rate. A separate exemption covers qualifying newly commencing businesses for their first three accounting periods.5
The local and global minimum top-up tax is a different regime. It targets qualifying multinational groups whose consolidated annual revenue exceeds the statutory EUR 750 million-equivalent threshold in at least two of the preceding four accounting periods. Its 15% minimum uses a separate jurisdictional effective-tax calculation, with exclusions and safe harbours. A 25% Turkish headline rate does not, by itself, dispose of that analysis.6
A 2026 investment model should distinguish the 2027 production rate
For 2026, qualifying manufacturing earnings remain subject to the existing one-percentage-point reduction; qualifying export earnings have a separate five-point reduction, with allocation and anti-stacking rules. Law No. 7582 replaces the production provision with a 12.5% rate for qualifying industrial and agricultural production earnings, but that change applies to earnings for 2027 and later periods, including the specified special accounting periods. It must not be presented as the general 2026 rate.7
The same 2026 law introduces substantial deductions for qualifying offshore goods trading and qualifying service-centre earnings, with separate conditions and commencement rules. These are activity-based provisions, not a blanket concession to every foreign-owned company. Eligibility, required transfers to Turkey, income allocation and the interaction with minimum tax should be confirmed before the benefit is included in a forecast.8
Inflation accounting is also period-sensitive
Tax Procedure Law Temporary Article 37 suspends the specified tax inflation adjustments for 2025, 2026 and 2027, with special-period rules and an exception for taxpayers within repeated Article 298(A)(9), concerning the prescribed processed gold and silver activities. Group financial reporting and Turkish tax accounting should therefore be reconciled rather than assumed to produce identical figures.9
3. VAT: classification matters more than a broad product label
The standard VAT rate is 20%; the scheduled reduced rates are 10% and 1%. Decision No. 7346 raised the former 18% and 8% rates from 10 July 2023. Most foodstuffs within the relevant scheduled category moved to 1% in February 2022. It is therefore incorrect to list basic food generally as a 10% category. A food sale and a restaurant service may have different treatment.10
Qualifying printed books and periodicals are generally exempt under Article 13(n), subject to its exclusions; they should not simply be assigned to the 10% list. The exemption does not automatically extend to electronic publications, accessories or every product sold in a bundle. Obtain a product-by-product classification, including relevant tariff information, rather than copy a competitor’s invoice rate.11
Input VAT is ordinarily deductible against output VAT when the statutory conditions, supporting documents and relevant timing requirements are met. A credit balance is not an unrestricted right to an immediate cash refund. Exempt or non-business activity, restricted purchases and refund-specific requirements can change the result. The financial model should distinguish deductible VAT, carried-forward VAT, refund-eligible VAT and irrecoverable VAT.12
Services supplied from abroad may engage Turkish reverse-charge VAT where the statutory territorial and responsibility conditions are met. Test where the service is performed or used and whether an exemption applies. Corporate withholding and VAT require separate analyses: treaty relief from income tax does not itself exempt a transaction from VAT.13
4. Dividends, branch remittances and treaty relief
The domestic withholding rate for covered dividend distributions is 15%, effective from 22 December 2024 under Decision No. 9286. It is not a uniform charge on every shareholder: the recipient’s status matters. Dividends paid to an ordinary fully taxable Turkish corporate recipient do not carry the same treatment as distributions to a non-resident corporate parent outside a Turkish permanent establishment.14
For a non-resident company filing an annual or special return, Article 30(6) addresses the relevant after-tax profit transferred to its head office. The domestic rate is likewise 15%, subject to treaty analysis. Describing all retained branch profit as automatically remitted is too broad. The accounts, actual transfers and any legally deemed distributions must be examined together.15
Consider a simplified example: TRY 100 of taxable profit, 25% corporate tax, and distribution of the remaining TRY 75 to a covered foreign shareholder at 15% withholding. The two Turkish taxes total TRY 36.25, leaving TRY 63.75. They do not total 40% of the original profit. This illustration assumes no relief, treaty reduction, different tax base or additional charge.
Treaty relief depends on the actual treaty, income classification and recipient. Residence evidence is important, but a certificate alone cannot establish beneficial ownership, satisfy a participation condition or overcome an applicable anti-abuse rule. Some treaty limits do not improve on the domestic rate. Obtain the required certificate and translation in advance, and record why the selected article and rate apply.16
Do not apply the dividend rate to every cross-border payment. Interest, royalties, professional services and ordinary business services follow different rules; some payments may be exempt or treaty-protected. The withholding point may arise on payment or crediting, not merely on a later bank transfer. Review gross-up clauses so that the contract states who bears any Turkish tax that cannot lawfully be reduced.17
5. Intercompany financing, royalties and management charges
Article 13 applies the arm’s-length principle to related-party transactions. A defensible charge needs more than a signed group agreement. Establish the service or right supplied, its commercial benefit, the allocation method and supporting evidence. A management fee calculated as a percentage of turnover is not self-justifying merely because the same formula is used elsewhere in the group.18
Thin capitalisation under Article 12 generally concerns the relevant related-party debt exceeding three times opening-period equity at any point during the accounting period, subject to statutory exceptions. It is not solely a year-end ratio. Interest, foreign-exchange differences and similar expenses attributable to thin capital are non-deductible; interest and similar amounts, but not foreign-exchange differences, can also be treated as distributed profit for the statutory purposes.19
A financing review should connect the loan balance, equity movements, pricing, withholding and deduction limits. Branch payments to a head office also have particular restrictions. The answer is not simply to replace interest with a service fee: a different label does not supply a service, remove a related-party relationship or establish deductibility.20
6. Stamp tax, payroll and transaction-specific charges
Stamp tax applies to documents within the statutory schedule, not to every contract or corporate resolution. Liability may be fixed or proportional and may be affected by a ceiling or exemption. Company formation and specified capital transactions have their own reliefs. Documents executed abroad can become relevant when used in Turkey. Signature and the payment deadline are not universally the same event.21
Before signing, identify the taxable document, stated monetary obligations, number and function of instruments, foreign-currency conversion and any amendment or guarantee. A contractual clause allocating the expense between the parties should not be mistaken for a release from liability to the tax administration.
Payroll requires a separate budget for employer and employee social-insurance obligations, applicable earnings bases and ceilings, and wage withholding. For personnel seconded from abroad, investigate the relevant social-security agreement and evidence of coverage rather than assume that payment overseas removes Turkish obligations. Sectoral charges, including special consumption tax and banking and insurance transaction tax, require transaction-specific review.22
7. Filing, evidence and tax disputes
Corporate tax is self-assessed. The annual return ordinarily falls in the fourth month after the accounting period ends. For calendar-year 2025 earnings, GİB specified 1-30 April 2026. Law No. 7566 restored the fourth advance-tax period for periods beginning from 1 January 2025. A compliance calendar limited to three provisional returns is therefore outdated.23
Advance tax is a payment towards the final liability, not a second annual corporate tax. The company should reconcile advance payments, withholding credits and allowable foreign tax credits, while separately monitoring VAT, payroll, electronic ledgers and other registrations. Assign responsibility for checking GİB’s live calendar and extension announcements; a group reporting deadline is not the Turkish filing deadline.24
The ordinary assessment limitation under Article 114 of the Tax Procedure Law is five years from the beginning of the calendar year following the year in which the tax claim arose. Both assessment and notification matter. Special rules, suspension and the separate collection limitation must be considered. This is not permission to destroy every underlying document after five years, particularly where longer corporate retention duties or continuing disputes apply.25
A disputed position can lead to tax, interest and penalties; criminal consequences require their own statutory elements. The ordinary tax-loss penalty is generally one times the lost tax, while specified conduct connected with Article 359 can engage a threefold penalty. Not every delay is tax evasion, and an audit finding is not itself a criminal conviction.26
For a tax-court action, the general period is 30 days unless a special provision applies, with the starting event determined by Article 7 of Law No. 2577. Obtain the notice and service record immediately. A correction request, negotiation or a reservation placed on a return does not automatically preserve every remedy or suspend collection. Counsel should identify the correct procedure before the company files, pays or waives a disputed item.27
8. Constitutional Court guidance: legality and a real opportunity to challenge
In Türkiye İş Bankası A.Ş., Application No. 2014/6192, 12 November 2014, the Constitutional Court addressed the legality requirement for interference with property. Its official case-law account emphasises that tax-related interference needs sufficiently accessible and foreseeable rules, not merely a formal reference to legislation. The principle does not freeze tax law or guarantee that every uncertain interpretation will be resolved in the taxpayer’s favour.28
In Arbay Petrol and Arbay Turizm, Application No. 2015/15100, 27 February 2019, companies filed amended VAT returns with reservations after administrative pressure concerning allegedly false supplier invoices. The Court found a property-rights violation because the resulting tax challenges were rejected without effective examination of their substance. Its official summary explains why the actual purchases and objections needed meaningful scrutiny.29
Arbay does not validate a false invoice or make every late amended return challengeable. Its practical importance is evidential and procedural: preserve the authority’s request, the reservation, the transaction records and the filing chronology. Administrative compliance and preservation of judicial rights should be planned together.
9. Instructing Turkish advisers from abroad
A foreign parent should distinguish preparation of returns from legal structuring and litigation. Agree which tasks belong to the company’s accountant, certified or sworn-in certified public accountant, Turkish lawyer and home-country adviser. Verify professional status and settle responsibility for submissions, signatures, electronic notices and urgent escalations in writing.30
For the first consultation, provide the ownership chart, accounting year, activities and licences, intercompany agreements, loan terms, major contracts, recent returns, outstanding credits and notices. Ask for an issue-specific assessment, a calculation of the cash exposure and a deadline list. A promised tax saving without examination of the transactions is not a substitute for that work.
Frequently asked questions
Is 25% the total tax cost of a Turkish subsidiary?
No. It is the ordinary corporate income tax rate, not a combined charge covering VAT, distributions, payroll and transaction taxes. The effective cost depends on the tax base, available relief and how profits are used or distributed.
Is the new production rate already 12.5% in 2026?
No. The enacted replacement production rate applies to the specified earnings for 2027 and later accounting periods. The existing 2026 rate reductions and eligibility rules must be assessed separately.
Do the 10% and 15% minimum taxes apply to every company?
No. The domestic 10% minimum and the multinational 15% top-up are distinct regimes with different bases, scope and exclusions. Neither is a simple surcharge added to 25%.
Does a tax treaty always reduce dividend withholding?
No. The relevant treaty must provide an advantage and its conditions must be met. Residence evidence is necessary in the prescribed procedure, but does not by itself establish every substantive entitlement.
Can a branch retain profit without automatic remittance withholding?
Article 30(6) addresses the relevant profit transferred to the head office. Retention and transfer should be distinguished, while separately checking any deemed-distribution or adjustment rule.
Can the company recover every lira of input VAT?
No. Deductibility, carry-forward treatment and refund eligibility are separate. The transaction, documentation, restrictions and applicable procedure determine the outcome.
Is a shareholder loan deductible if its interest rate is reasonable?
Not necessarily. Arm’s-length pricing does not displace thin-capitalisation or other expense restrictions. The debt and opening equity must be reviewed alongside the terms and use of funds.
What should happen immediately after a tax notice arrives?
Preserve the notice, service record and supporting file, and obtain advice on the remedy and deadline. Do not assume that discussions with an officer extend the time to bring a claim.
Conclusion
A workable Turkish tax structure connects the entity, activity, accounting period and payment flow. Corporate tax residence should be settled before profit attribution; VAT classification before pricing; treaty entitlement before distribution; and financing restrictions before a loan is drawn. The 2026 and 2027 changes reinforce the importance of those distinctions. For a foreign-owned business, the strongest practical safeguard is a documented position that the finance team can implement, the board can understand and counsel can defend. Tax planning should reduce avoidable uncertainty without replacing statutory conditions with assumptions or overlooking the procedural steps needed to preserve a legitimate claim.
Bibliography
Online materials consulted on 21 September 2026. Statutes are cited as amended; historical enactments and non-binding administrative or court summaries are identified where used.
Legislation and Treaties
Corporate Tax Law No. 5520, particularly arts. 3, 6, 9, 11-15, 22, 30 and 32-34. Official Gazette No. 26205, 21 June 2006. Original enactment read with subsequent amendments and current GİB guidance. https://cdn.tbmm.gov.tr/KKBSPublicFile/D22/Y4/T1/KanunMetni/25e7e494-eb5b-4ca0-8b12-0f3beffdd782.html
Value Added Tax Law No. 3065, particularly arts. 1, 6, 9, 13(n), 28-30, 32 and 34. Official Gazette No. 18563, 2 November 1984, as amended. https://gib.gov.tr/mevzuat/kanun/436
Stamp Tax Law No. 488, arts. 1, 3, 10, 14 and 22 and attached Tables I and II. Official Gazette No. 11751, 11 July 1964, as amended. https://gib.gov.tr/mevzuat/kanun/438
Tax Procedure Law No. 213, particularly arts. 107/A, 112, 114, 253, 341, 344, 359 and 378, as amended. https://gib.gov.tr/mevzuat/kanun/434
Administrative Judicial Procedure Law No. 2577, particularly arts. 7 and 27. Official Gazette No. 17580, 20 January 1982, as amended. https://gib.gov.tr/mevzuat/kanun/452
Social Insurance and General Health Insurance Law No. 5510, particularly arts. 80-82, as amended. Official Gazette No. 26200, 16 June 2006. https://www.mevzuat.gov.tr/MevzuatMetin/1.5.5510.pdf
Law No. 7456, art. 21, amending the corporate tax rates and qualifying export-rate reduction in Corporate Tax Law art. 32. Official Gazette No. 32249, 15 July 2023. https://cdn.tbmm.gov.tr/KKBSPublicFile/D27/Y6/KanunMetni/307c8ce5-3d8b-4d86-8439-abae345e7626.htm
Law No. 7524, particularly arts. 35-46 and 60: Corporate Tax Law art. 32/C and the local and global minimum top-up tax provisions. Official Gazette No. 32620, 2 August 2024. https://cdn.tbmm.gov.tr/KKBSPublicFile/D28/Y2/KanunMetni/885b55a7-4db6-48c3-88b8-5c1653298048.htm
Law No. 7566, art. 2, amending Income Tax Law No. 193, repeated art. 120; commencement provisions. Official Gazette No. 33112, 19 December 2025. https://www.gib.gov.tr/mevzuat/kanun/651
Law No. 7571, art. 34, inserting Tax Procedure Law Temporary art. 37. Official Gazette No. 33118, 25 December 2025. https://cdn.tbmm.gov.tr/KKBSPublicFile/D28/Y3/KanunMetni/5189159c-4dec-44bf-87e0-9b23a810c791.htm
Law No. 7582, arts. 6-9 and 14, including the separate commencement rules for earnings deductions and the production rate. Official Gazette No. 33270, 4 June 2026. https://cdn.tbmm.gov.tr/KKBSPublicFile/D28/Y4/KanunMetni/4b916eb3-fb9a-4f40-aea8-3c044342be21.htm
Presidential Decision No. 9286, Official Gazette No. 32760, 22 December 2024. The effective date and 15% dividend withholding rate are also confirmed in GİB, Menkul Sermaye İradı. https://www.resmigazete.gov.tr/eskiler/2024/12/20241222-15.pdf
Income Tax Law No. 193, including wage withholding and repeated art. 120, as amended. https://gib.gov.tr/mevzuat/kanun/433
Public Receivables Collection Law No. 6183, particularly art. 102; Turkish Commercial Code No. 6102, particularly art. 82, as amended. https://www.mevzuat.gov.tr/MevzuatMetin/1.5.6183.pdf
Special Consumption Tax Law No. 4760 and Expenditure Taxes Law No. 6802, as amended. Sectoral rates are not tabulated in this article. https://www.mevzuat.gov.tr/MevzuatMetin/1.5.4760.pdf
Attorneyship Law No. 1136 and Law No. 3568 on independent accountancy, certified public accountancy and sworn-in certified public accountancy, as amended. https://www.mevzuat.gov.tr/MevzuatMetin/1.5.1136.pdf https://www.mevzuat.gov.tr/MevzuatMetin/1.5.3568.pdf
Judicial Decisions
Constitutional Court, Türkiye İş Bankası A.Ş. [General Assembly], Application No. 2014/6192, 12 November 2014. https://kararlarbilgibankasi.anayasa.gov.tr/BB/2014/6192
Constitutional Court, Arbay Petrol Gıda Turizm Taşımacılık Sanayi Ticaret Ltd. Şti. and Arbay Turizm Taşımacılık İthalat İhracat İnşaat ve Organizasyon Sanayi ve Ticaret Ltd. Şti. [General Assembly], Application No. 2015/15100, 27 February 2019. https://kararlarbilgibankasi.anayasa.gov.tr/BB/2015/15100
Institutional and Official Materials
Revenue Administration (GİB), Kurumlar Vergisi Beyan Rehberi, Publication No. 606, March 2026, especially the residence, rate, minimum-tax and filing sections. Later amendments are separately identified in this article. https://cdn.gib.gov.tr/api/gibportal-file/file/getFile?objectKey=DUYURU/UNIVERSAL/2026/2026_Kurumlar_Vergisi_Beyan_Rehberi.pdf
GİB, ruling E-39044742-135-1431578, 11 December 2023, reproducing the applicable VAT rate decisions: Council of Ministers Decision No. 2007/13033, as amended by Presidential Decisions Nos. 5189 and 7346. This includes the transfer of scheduled foodstuffs to List I. https://gib.gov.tr/mevzuat/kanun/436/ozelge/32100
GİB, ruling E-39044742-130[Özelge]-1428871, 14 October 2024, reproducing VAT Law art. 13(n) and VAT General Application Communiqué II/B-17.1 on printed books and periodicals. https://gib.gov.tr/mevzuat/kanun/436/ozelge/38637
GİB, Menkul Sermaye İradı, section on dividends from resident companies, identifying the 15% rate effective from 22 December 2024 under Decision No. 9286. https://gib.gov.tr/vergi-konulari/1_bireysel/10_menkul_sermaye_iradi/10
GİB, official ruling on payments to an Italian resident, including the residence-certificate and certified Turkish translation requirements. The procedural explanation is cited, not a universal service-payment rate. https://gib.gov.tr/mevzuat/kanun/433/ozelge/20799
GİB, official ruling on the taxable event and limitation period for stamp tax, reproducing Stamp Tax Law arts. 1, 3 and 12 and Tax Procedure Law arts. 19 and 114. https://gib.gov.tr/mevzuat/kanun/438/ozelge/25047
Constitutional Court, Mülkiyet Hakkına Dair Emsal Kararlar Tüm Liste, section on legality and foreseeability, citing Türkiye İş Bankası A.Ş., Application No. 2014/6192. https://www.anayasa.gov.tr/tr/bireysel-basvuru/temel-hak-ve-ozgurluklerin-ihlaline-dair-emsal-kararlar/mulkiyet-hakkina-dair-emsal-kararlar/mulkiyet-hakkina-dair-emsal-kararlar-tum-liste
Constitutional Court, press release BB 22/19, 3 April 2019, on reserved amended returns and effective judicial review in Arbay, Application No. 2015/15100. The Court identifies this summary as non-binding. https://anayasa.gov.tr/tr/haberler/bireysel-basvuru-basin-duyurulari/ihtirazi-cekinceli-kayitla-verilen-duzeltme-beyannameleriyle-ilgili-acilan-vergi-davalarinin-esastan-incelenmeden-reddi-nedeniyle-mulkiyet-hakkinin-ihlal-edilmesi/
GİB, Vergi Takvimi, official tax calendar. Filing extensions and special-period dates must be checked for the particular obligation. https://gib.gov.tr/vergi-takvimi
Footnotes
1. Corporate Tax Law No. 5520, art. 3(1)-(6); GİB, 2026 return guide, sections on full and limited liability. Law No. 5520; GİB return guide
2. Corporate Tax Law, arts. 3, 22 and 30. The domestic source rules must be read with the specific applicable double-tax treaty. Law No. 5520
3. Corporate Tax Law, art. 32(1), as amended by Law No. 7456 and Law No. 7524; GİB, 2026 return guide, pp. 67-70, including the rate table. GİB return guide; Law No. 7456; Law No. 7524
4. Corporate Tax Law, arts. 6, 8-11, 33 and 34; GİB, 2026 return guide, computation, losses and tax-credit sections. Law No. 5520; GİB return guide
5. Law No. 7524, art. 36, introducing Corporate Tax Law art. 32/C, and art. 60; GİB, 2026 return guide, pp. 72-78. The scope of the startup rule and excluded deductions requires individual review. Law No. 7524; GİB return guide
6. Corporate Tax Law, additional arts. 1-10 and related transitional provisions, inserted by Law No. 7524, arts. 37-46. The EUR threshold is a group test, not the Turkish subsidiary’s standalone turnover. Law No. 7524
7. Corporate Tax Law, art. 32(7)-(8); GİB, 2026 return guide, rate section; Law No. 7582, arts. 8 and 14(c). GİB return guide; Law No. 7582
8. Law No. 7582, arts. 6, 7, 9 and 14(b): Foreign Direct Investment Law additional art. 1 and Corporate Tax Law art. 10(1)(i)-(j), with changes to art. 32/C. Law No. 7582
9. Law No. 7571, art. 34, inserting Tax Procedure Law Temporary art. 37. This paragraph concerns the tax rule, not a conclusion on the group’s financial-reporting standards. Law No. 7571
10. VAT Law, art. 28; Decisions Nos. 2007/13033, 5189 and 7346. GİB ruling E-39044742-135-1431578, 11 December 2023, reproduces the rate changes and food-list rules. GİB rate ruling
11. VAT Law, art. 13(n); VAT General Application Communiqué II/B-17.1, reproduced in GİB ruling E-39044742-130[Özelge]-1428871, 14 October 2024. GİB publication ruling
12. VAT Law, arts. 29, 30, 32 and 34. Deduction and refund are separate legal mechanisms. VAT Law
13. VAT Law, arts. 1, 6 and 9. The service’s use, the supplier’s establishment and applicable exceptions must be assessed separately. VAT Law
14. Presidential Decision No. 9286; Corporate Tax Law, arts. 15 and 30(3); GİB, Menkul Sermaye İradı, current rate explanation. Decision No. 9286; GİB dividend guidance; Law No. 5520
15. Corporate Tax Law, art. 30(6), read with Decision No. 9286 and any applicable treaty. Thin-capitalisation and transfer-pricing adjustments can create separate deemed-distribution consequences. Law No. 5520; Decision No. 9286
16. GİB official ruling on payments to an Italian resident, residence-certificate and certified Turkish translation requirements. Treaty entitlement and the substantive taxing provision require their own examination. GİB treaty procedure
17. Corporate Tax Law, art. 30(1)-(3) and its implementing rate decisions. Payment classification precedes selection of a domestic or treaty rate. Law No. 5520
18. Corporate Tax Law, art. 13, particularly the arm’s-length and documentation requirements; art. 11(1)(c). Law No. 5520
19. Corporate Tax Law, arts. 11(1)(b) and 12(1), (3)(b), (6)-(7). The equity definition and statutory exclusions matter. Law No. 5520
20. Corporate Tax Law, arts. 11-13 and 22(3). Other financing-expense restrictions require a separate computation where applicable. Law No. 5520
21. Stamp Tax Law, arts. 1, 3, 10, 14 and 22 and Tables I-II; GİB ruling on the taxable event and limitation period. Stamp Tax Law; GİB stamp-tax ruling
22. Law No. 5510, arts. 80-82; Income Tax Law No. 193, wage-withholding provisions; Special Consumption Tax Law No. 4760 and Expenditure Taxes Law No. 6802. This guide does not quote sector rates or annual payroll ceilings. Law No. 5510
23. Corporate Tax Law, arts. 14, 21 and 32(2); Law No. 7566, art. 2; GİB, 2026 return guide, pp. 71 and 79. Published extensions and special accounting periods must be checked. Law No. 7566; GİB return guide
24. Corporate Tax Law, arts. 33-34; GİB, Vergi Takvimi and the 2026 return guide’s credit and payment sections. Law No. 5520; GİB calendar
25. Tax Procedure Law, arts. 114 and 253; Public Receivables Collection Law No. 6183, art. 102; Turkish Commercial Code, art. 82. Tax Procedure Law
26. Tax Procedure Law, arts. 112, 341, 344 and 359, as amended. Procedural penalties and criminal offences should be distinguished from the ordinary tax-loss penalty. Tax Procedure Law
27. Administrative Judicial Procedure Law, arts. 7 and 27; Tax Procedure Law, art. 378. Different assessments, own-return cases and collection measures can require different procedures. Law No. 2577; Tax Procedure Law
28. Constitutional Court, Türkiye İş Bankası A.Ş. [General Assembly], Application No. 2014/6192, 12 November 2014. This account uses the Court’s official property-rights case-law summary; it does not present a new full-judgment analysis. Case record; Court case-law summary
29. Constitutional Court [General Assembly], Arbay Petrol Gıda Turizm Taşımacılık Sanayi Ticaret Ltd. Şti. and Arbay Turizm Taşımacılık İthalat İhracat İnşaat ve Organizasyon Sanayi ve Ticaret Ltd. Şti., Application No. 2015/15100, 27 February 2019; official non-binding summary BB 22/19, 3 April 2019. Case record; Court press summary
30. Law No. 3568 and Attorneyship Law No. 1136, particularly the respective professional functions. A written scope should identify responsibility for accounting, certification and representation. Law No. 3568
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
