Tax

Our services

• Management of tax-audit processes. Conduct of the process from the start of the audit, preparation of replies to requests for information and documents, assessment of audit minutes, use of mechanisms such as the invitation to explain, and representation before report-evaluation commissions.
• Tax disputes. Representation on settlement applications and in settlement meetings, applications by way of correction and complaint, actions before the tax courts, appeal and cassation, and applications for a stay of execution.
• Tax criminal law. Proceedings relating to tax-loss and irregularity penalties, defence in investigations and prosecutions for smuggling offences, and the handling of allegations of false or misleading documents.
• Corporate structuring and reorganisation. Assessing the tax consequences of mergers, divisions, changes of type and share transfers, reviewing intra-group structures, and liquidation processes.
• Transaction-focused tax review. Identifying the target’s tax risks in mergers and acquisitions, reflecting the risks identified in the transaction documents through disclosure, covenant and indemnity provisions, and a comparative assessment of the transaction structure from a tax perspective.
• International taxation. Application of double-tax treaties, taxation on the limited-liability basis, assessments of whether a permanent establishment arises, withholding obligations on payments made abroad, and controlled-foreign-company rules.
• Transfer pricing. Setting pricing policies for transactions with related persons, fulfilling documentation obligations, advance pricing agreements, and defence against transfer-pricing challenges.
• Value-added tax and other indirect taxes. Conduct of refund processes, assessments of exemption and deduction practice, and special-consumption-tax and stamp-tax practice.
• Customs and foreign-trade taxes. Disputes on customs value and tariff classification, rules of origin, additional financial liabilities, and objection processes and actions before the customs administration.
• Taxation of the digital economy. Application of the digital-services tax, taxation and filing obligations for services supplied by electronic means, and the tax liability in Türkiye of providers established abroad.
• Taxation of the financial sector. The tax dimension of credit and financing transactions, the banking and insurance transactions tax, resource-utilisation support-fund deductions, and the taxation of financial instruments.
• Real-estate and project taxation. Tax obligations on the acquisition and transfer of immovable property, the tax consequences of construction-for-land and revenue-sharing models, and property-tax and valuable-housing-tax practice.
• Taxation of remuneration and executives. Taxation of employees and managers, the position of personnel assigned from abroad, and the tax framework of share-based incentive plans.
• Incentive and exemption practice. Tax advantages under an investment-incentive certificate, free-zone and technology-development-zone practice, and the research-and-development deduction.
• Wealth and asset management. Tax planning of generational transition in family companies, inheritance and transfer transactions, and the rules on the declaration of assets held abroad.

How we work

On tax files it is often unavoidable to work together with certified public accountants and independent auditors. We prefer to separate the roles at the outset: the calculation and filing side is the accountant’s; the legal basis of the obligation and the dispute strategy are ours. A clear separation prevents the two sides from giving explanations that contradict each other at the audit stage.

Time limits in tax disputes are strict and cannot be made good once missed. On the first day of the file we draw up a calendar that includes the periods for application, settlement and bringing an action, and we run the process against that calendar.