Tax Practises
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The service provided by the US resident company within the scope of the international patent application is considered as a self-employment activity and the taxation right of the income obtained by the US resident company due to the service in question belongs only to the USA, unless the activities in question are performed in Turkey
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The services provided by limited taxpayer organisations in Turkey under the name of management and consultancy services are considered as know-how, i.e. technical know-how, if they meet the 5 conditions (Knowledge/Experience; Obligation; Materiality; Materiality; Transfer; Confidentiality)
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Since it is understood from the examination of the tax technique report issued about the company from which the invoice was received that the invoices issued by the said taxpayer are not based on a real delivery of goods and services, there is no contradiction to the law in the penalty assessments made due to the invoices in question
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