Our firm provides comprehensive legal counsel on all aspects of direct taxation in Turkey, representing corporate and individual clients in both contentious and advisory matters. We analyze complex tax law issues, assess legal risks, and develop defensible tax positions that align with Turkish domestic law and international tax principles. Our practice combines rigorous legal analysis with practical dispute resolution experience, enabling us to advise on tax compliance requirements, evaluate the sustainability of tax positions under scrutiny, and advocate effectively when disputes arise. We focus on legally sound solutions that protect our clients' interests while supporting their legitimate business objectives.

Here are some direct tax topics among our capabilities:

i. Corporate Taxation

ii. Individual Taxation

iii. International Taxation

iv. Business Restructurings

v. Transfer Pricing

vi. Subsidies, Grants and Incentives

vii. Taxes on Wealth

The following sections describe the details of our capabilities in each topic:

i. Corporate Taxation

Turkish corporate income tax applies to resident corporations on their worldwide income and to non-resident corporations on Turkish-source income. The corporate tax system involves complex rules concerning deductible expenses, exempt income, loss utilization, taxation of distributions, thin capitalization limitations, and transfer pricing requirements for related-party transactions. Our firm provides comprehensive legal counsel on corporate taxation matters, analyzing the application of tax law to business structures and transactions, interpreting new legislation and regulatory guidance, assessing legal risks in corporate tax positions, and representing clients in audits and disputes concerning corporate tax assessments. We advise on the tax law implications of corporate transactions, evaluate the defensibility of tax positions against potential challenges, and develop legally sound approaches to corporate tax compliance. Our expertise helps companies navigate Turkish corporate tax law while managing legal risk and ensuring their tax positions can withstand administrative and judicial scrutiny.

ii. Individual Taxation

Individual income tax in Turkey applies to residents on worldwide income and to non-residents on Turkish-source income, with progressive rates and various categories of income subject to different rules. Personal tax matters involve coordination between income tax, social security contributions, and wealth taxes. Personal income rules cover employment, self-employment, capital gains and residency-based taxation. International assignments, secondments, executive compensation, and expatriate packages create legal exposure for both employer and employee under Turkish tax law. Our firm provides legal counsel to individual clients, including employees of multinational corporations, corporate executives, entrepreneurs, investors, expatriates, and high-net-worth individuals, on all aspects of personal taxation. We analyze the tax law treatment of compensation arrangements, investment structures, and wealth management strategies, assess legal risks and compliance obligations, evaluate the defensibility of tax positions, and represent individuals in disputes with tax authorities concerning income tax assessments and penalties. Our expertise helps clients understand their legal obligations, structure their affairs in accordance with Turkish tax law, and defend their positions when challenged by tax authorities.

iii. International Taxation

Turkey's extensive tax treaty network and domestic international tax rules create complex legal issues and compliance obligations for cross-border transactions. International taxation matters include permanent establishment exposure, withholding tax obligations, treaty benefit entitlements, transfer pricing compliance, and controlled foreign corporation rules. Our firm specializes in international tax law, providing legal counsel to multinational enterprises and Turkish companies on the tax law implications of cross-border transactions, analyzing permanent establishment risk, interpreting tax treaty provisions for proper allocation of taxing rights, evaluating withholding tax obligations and exemptions, and assessing compliance with international tax reporting requirements. We analyze the application of Turkish domestic law and bilateral tax treaties to specific cross-border arrangements, evaluate the legal defensibility of treaty benefit claims, advise on avoiding double taxation through proper treaty interpretation and application, and represent clients in disputes with tax authorities on international tax issues. Our expertise helps clients structure international operations in accordance with Turkish tax law and international tax standards, including OECD guidelines and treaty obligations, while managing legal risks and ensuring their positions can withstand scrutiny from multiple tax jurisdictions.

iv. Business Restructurings

Corporate restructurings—including mergers, spin-offs, asset transfers, and acquisitions—carry significant tax law implications under Turkish law. While certain restructurings can qualify for tax neutrality, strict legal requirements must be satisfied to avoid deemed disposal treatment and associated tax liabilities. Our firm provides comprehensive legal counsel on the tax aspects of business restructurings, analyzing the application of tax law to alternative restructuring forms, evaluating whether transactions meet the legal criteria for tax-neutral treatment, and advising on compliance with statutory conditions and procedural requirements. We assess the legal risks of proposed structures, evaluate the defensibility of tax positions against potential challenges from tax authorities, and facilitate restructuring transactions that achieve business objectives while maintaining compliance with Turkish tax law. When restructurings are challenged during audits or result in disputes, we represent clients before administrative authorities and courts, defending the legal validity of restructuring structures and arguing for tax-neutral treatment. Our expertise helps clients execute restructurings in accordance with Turkish tax law while managing legal exposure and ensuring their structures can withstand scrutiny.

v. Transfer Pricing

Turkish transfer pricing rules require that related-party transactions comply with arm's length principles, supported by contemporaneous documentation. Non-compliance can result in substantial adjustments, penalties, and increased scrutiny. Our firm provides comprehensive legal counsel on transfer pricing matters, analyzing the application of arm's length principles to intra-group transactions, advising on transfer pricing policies consistent with OECD principles and Turkish legal requirements, evaluating the legal defensibility of pricing methodologies, and preparing documentation that supports legally sustainable positions. We assess compliance with Turkish transfer pricing documentation requirements, coordinate with clients' advisors on benchmarking analyses to support arm's length pricing, and evaluate legal risks in existing transfer pricing arrangements. When transfer pricing positions are challenged during audits, we represent clients before tax authorities defending the legal and economic basis of related-party pricing. In transfer pricing disputes and litigation, we represent clients before courts, presenting legal arguments and expert evidence to establish compliance with arm's length principles. Our transfer pricing practice combines rigorous legal analysis with economic and financial expertise to develop defensible positions capable of withstanding judicial review.

vi. Subsidies, Grants and Incentives

Turkey offers various investment incentives, regional support programs, R&D incentives, and sectoral subsidies designed to stimulate strategic investment, technological development, and specific prioritized economic activities. These programs provide valuable tax benefits, including corporate tax reductions, exemptions, VAT advantages, and social security support, subject to strict qualification requirements and ongoing compliance obligations under law. Proper qualification unlocks material financial benefits, while non-compliance or mismanagement risks clawbacks, penalties, and loss of incentive status. Our firm provides legal counsel on incentive and subsidy matters, analyzing eligibility criteria under applicable legislation, evaluating the legal requirements for qualification and maintenance of incentive status, advising on compliance with statutory conditions and reporting obligations, and assessing legal risks in incentivized arrangements. We represent clients in audits of incentivized activities, defending incentive qualifications before administrative authorities. When incentive benefits are challenged, denied, or subject to clawback proceedings, we represent clients before courts, presenting legal arguments to establish compliance with incentive legislation and preserve tax benefits. Our expertise helps clients access Turkish incentive programs in accordance with legal requirements while managing compliance risks and defending their entitlements when disputed.

vii. Taxes on Wealth

Turkish wealth taxation includes inheritance and gift tax, property tax, mansion tax on high-value residences, and motor vehicle tax, with rates and exemptions that vary based on asset type and taxpayer status. While not technically a tax, title deed fees on real estate transfers also constitute a significant cost consideration in wealth management and planning. Wealth transfer planning requires careful analysis of valuation rules, exemption thresholds, and filing requirements under tax law. Asset transfers and property dealings can create substantial tax liabilities if legal requirements are not properly addressed. Our firm provides legal counsel on wealth tax matters, analyzing the application of wealth tax laws to asset transfers and property transactions, evaluating legal strategies for structuring wealth transfers in accordance with Turkish tax law, advising on compliance with wealth tax filing and reporting requirements, and assessing legal risks in wealth planning arrangements. We represent clients in wealth tax disputes and litigation before courts, challenging excessive valuations, establishing proper application of exemptions, and defending wealth transfer structures to help high-net-worth individuals and families structure wealth transfers in compliance with Turkish tax law and protect their positions against challenges from tax authorities.