Tax legislation never stands still, a new provision enters into force and another is invoked or altered literally day by day. Thus, legislative environment of tax issues should be followed closely in order to be fully compliant. Tax codes, a path to walk along with care, not only imply duties and obligations but also provide taxpayers with a broad range of tax exceptions, allowances and tax credits as part of incentive policies. Inadvertency or negligence may cause tax, penalties and interest cost. Minimizing tax costs and effective usage of tax benefits without causing any tax evasion is aim of all businesses. We are at your service to achieve this goal. Below, you may have a look at some of the services we offer.

It is crucial to design an efficient tax structure and to calculate tax burden for identifying the right return to capital ratio, especially when investing in a new jurisdiction and or industry. Many times, timing of decisions and method of applications of these decisions may yield to financial advantages or burdens. Our tailored consultancy services aims to direct businesses in the right direction.

Both domestic and international groups may face tax penalties if they set transaction prices not compatible with arms length principle with related parties or in intra-group activities. Transfer pricing between related parties should be based on robust economic analysis and should be in compliance with transfer pricing regulations. Transfer pricing issues, being on the top line of tax debates, needs close follow up of both domestic regulations and OECD guidelines. Vague regulations, differing approaches of the Tax Authority and taxpayers, incompetent case law put taxpayers that have transactions with related entities in high risk in terms of transfer pricing penalties. Our service in this area includes:

• Determining arm’s length price or margin for a given transaction,

• Preparing statutory transfer pricing documents,

• Consultancy on transfer pricing audits and disputes

• Consultancy for advance pricing agreements (APA)

• Consultancy about applying court or not

Cross border transactions and investments are affected by differing tax codes of source and destination jurisdictions. Global web of Avoidance of Double Taxation agreements (DTAs) should be taken into account in order for implementing the most efficient transaction or investment. Tax burden and incentives in most cases become an important point to decide where and how to invest. In this regard, we provide both incoming and outgoing investees with consultancy on international tax matters.

Turkish Tax Codes (CIT, PIT, VAT and others) include a bunch of selective tax exemptions as a result of due to economic and social policies. Changes in these incentives are very common. For example, exemptions for sale - lease back, lease certificates come into force while others are altered or revoked. Some incentives and exemptions are permanent while some others are temporary. Incentives spread over several regulations should be taken into consideration and analyzed collectively. We review your records and give advisory service in order to be sure that you benefit from all of the exemptions that you are legally entitled to and complete the necessary procedures.

Advance tax rulings (ATR) are very important, especially for vague areas of tax code. Holder of tax ruling is protected against any tax penalty in the future. Thus, our service for obtaining an up to subject advance tax ruling will ensure your future transactions subject to ATR.

None of the tax payers enjoy tax audits. Nonetheless, audit taxpayers process should be governed carefully and professionally. Our advisory service throughout this process will provide you with • Awareness of your rights as a taxpayer

• Efficiency in preparing necessary documents,

• Professional communication with tax auditor(s),

• Forecasting the future route of the audit, any possible tax and penalty burden,

• Assistance in preparing your legal explanations to be included in audit statements

• Appealing to Audit Report Reading and Evaluation Commission

• Application for pre-assessment conciliation

Our advisory service during pre-application and postimplementation stages of e-invoice and e-book helps businesses in minimizing possible risks.