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Tax advisory services

A. Corporate tax advisory services

  • Consultancy on general applications of the Turkish Tax Legislation ( Income Tax Law, Corporation Tax Law, Tax Procedures Code, Value Added Tax Law etc.)
  • In addition to the tax news bulletins regularly providing new and explanations on the changes in Tax Legislation, further interpretation of the changes considering the specific circumstances of each company served
  • Analysis and evaluation of agreements concluded by companies (e.g. license, royalty, technical service, cost sharing agreements, distributor agreements, share transfer agreements etc.) as far as various tax liabilities are concerned
  • Technical support and consultancy on responding, in accordance with the Tax Procedures Code, to the official letters of information request, tax penalty notifications received from the Tax Authorities
  • Analysis and evaluation of taxation risks associated with various financing policies (e.g. thin capitalization)
  • Evaluation of the relations between different legislations such as Banking Law, Capital Market Law and the Tax Legislation to ensure full compliance
  • Technical support in applications to the Tax Administration to request Advance Rulings with regard to taxation applications which require clarification
  • Consultancy on taxes to be applied by Turkish companies with respect to the services received, intangible rights purchased from non-resident companies
  • Taxation analysis and evaluation of such financing models as “Financial Leasing”, Build-Operate-Transfer”, Build-Operate-Own”, “Transfer of Operating Rights”

B. International tax advisory services

    a. Applications of double tax treaties

  • Analysis of the operations constituting “Permanent Establishment” for tax purposes
  • Taxation of dividends paid to non-resident shareholders in both the source country and the country of residence
  • Taxation of the payments in return for intangible rights (license, know-how, royalty etc.)
  • Taxation of the payments made by Turkish companies to non-residents in return for performance of certain services
  • Analysis of methods of elimination of double taxation (exemption, credit methods) as well as the procedures to be followed to eliminate double taxation (mutual agreement procedure, exchange of information etc.) for various cases
  • Technical support and consultancy on withholding tax refund requests within the framework of the relevant provisions of the Double Tax Treaties

    b. Transfer pricing analysis

  • Analysis of operations between related parties
  • Comparison of prices applied between related and unrelated parties
  • Providing suggestions on applications within the framework of the relevant rules of the local legislation as well as the relevant provisions of the Double Tax Treaties

    c.  International tax planning

  • Technical support and consultancy on determination of the most tax-efficient investment models using the tax technology software developed by our global firm
  • Consultancy on international tax planning for investments planned by multinational enterprises, through ongoing exchange of information with our colleagues in other Deloitte offices all over the world, who are specialized in international taxation

    d.  Other international taxation applications

  • Taxation aspects of cross-border financial leasing transctions
  • Analysis of international movement of capital, securities and goods from the points of view of taxation as well as other fiscal liabilities (Legislation governing protection of Turkish Currency, Foreign Trade Legislation etc.)
  • Operations in Turkish Free Trade Zones
  • Analysis of Thin Capitalization for multinational enterprises
  • Technical support and consultancy on determination of the most tax efficient model of investment and operation for project companies with foreign capital that plan to invest in large public projects (dam/tunnel construction, power plant investments etc.), within the framework of the local legislation as well as the relevant provisions of Double Tax Treaties

C. Tax planning

  • Consultancy to ensure the most efficient use of  and benefit from tax exemptions and incentives governed by the Tax Legislation
  • Technical support and consultancy on determination of the most tax efficient model for companies considering the specific circumstances of the company served
  • Technical support and consultancy on strategic tax planning for multinational enterprises
  • Consultancy on restructuring/reorganization for tax purposes
  • Tax planning for individuals and sole proprietors

D. Consultancy on legislation governing protection of turkish currency, foreign trade, incentives and foreign direct investments

  • Consultancy on Legislation governing protection of Turkish Currency
  • Taxation aspects of “invisible transactions”
  • Application of “Resource Utilization Support Fund” (“KKDF”)
  • Consultancy on Incentive Legislation (investment allowance, VAT exemption, duty exemption etc.)
  • Tax liabilities in foreign trade transactions
  • Export Incentive Legislation
  • Other tax incentives
  • Consultancy on operations and applications within the framework of Foreign Direct Investment Act
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