As the global tax landscape undergoes a monumental shift with the implementation of the OECD’s Pillar 2 framework, Türkiye has positioned itself as a proactive early adopter. This has direct and significant consequences for the Turkish subsidiaries of multinational enterprises (MNEs), particularly those whose parent companies are based in jurisdictions implementing the new rules from…
A new legislative proposal, “Law Proposal on Amending the Law on the Protection of the Value of Turkish Currency and Certain Laws,” has been submitted to the Turkish Grand National Assembly (TBMM) on June 16, 2025. This proposal aims to combat informality, strengthen tax justice, limit deductions and exemptions, increase the share of direct taxes…
With the “Presidential Decree No.9160 on the Amendment of the Exemption Rate in Paragraph (e) of the First Clause of Article 5 of the Corporate Tax Income Law (the CIT) No. 5520” published in the Official Gazette dated November 27, 2024 and numbered 32735, the exemption rate under Article 5/1-e of the CIT Law has…
Turkey Introduces 7.5 Percent Digital Service Tax Turkey has enacted its digital service tax, together with an accommodation tax, luxury residence tax and other important tax amendments under law No. 7194, published on the Official Gazette dated December 7. To be subject to Turkey’s digital service tax, a company must have revenues in Turkey of…
A New Audit Wave for the Non-Resident Digital Companies Turkey: new tax audit wave focuses on nonresident digital companies Turkey’s government has initiated a new wave of tax audits scrutinizing the taxation of nonresident taxpayers engaged in the digital economy. Turkey’s Inspection Board of Ministry of Treasury and Finance has sent official audit letters to…
An Assessment of Free Trade Zones from a Transfer Pricing Perspective(*) 1. Introduction The term “free trade zone” (FTZ) refers to one or more special areas of a country in which certain normal trade barriers (e.g. tariffs and quotas) are eliminated and bureaucratic requirements are minimized in hopes of attracting new business and foreign investment.…
Temporary Obligations on Export Proceeds in Turkey Turkish Ministry of Finance and Treasury has recently issued a new Communique on the Protection of the Value of Turkish Currency concerning the activities of exporters in Turkey. The Communique was published on the Official Gazette on 4th of September 2018. In general, the newly issued Communique No.…
New Cabinet Decree on Transfer Pricing Article 13 of Corporate Income Tax Law, regulating transfer pricing rules, was amended through the Law No. 6728 on the Improvement of the Investment Environment and in this scope additional authority was given to the Turkish Cabinet to determine transfer pricing procedures. Turkish Revenue Administration (Turkish Tax Authority) prepared…
FX Restrictions on Certain Domestic Transactions Published in the Official Gazette on September 13, Amending Presidential Decree Regarding the Decree on Protection of the Value of the Turkish Currency (“Decree No. 32”) introduced FX restrictions on certain domestic transactions accomplished among Turkish residents. These transactions include sale and purchase of real estate, sale and purchase…
Developments in the Transfer Pricing Landscape 1. Introduction Turkey introduced its first transfer pricing rules in 2007, and the Turkish transfer pricing system was adopted from OECD guidance and based on the arm’s length principle. In the first year of implementation, the Turkish Cabinet determined the transfer pricing procedures based on the authority granted by…