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Cross-border Tax & Investment Advisory

Manage the Turkish side of inbound investment and the tax and reporting duties of Turkish outbound structures in one evidence-led map.

Scope

The analysis starts with residence, source, Turkish permanent-establishment or dependent-agent exposure, payment classification and beneficial ownership. Only then are the structure, contracts, transfer pricing and filing calendar designed. The engagement covers Turkish tax, accounting and financial regulation. Foreign law, local incorporation and foreign-country tax opinions require separate confirmation by an independently engaged professional authorised in that jurisdiction.

  • Türkiye-entry comparison: A.Ş./Ltd., branch, liaison office and permanent-establishment/dependent-agent exposure
  • Individual and corporate residence, including legal seat, place of effective management and dual-residence questions
  • Article 20/D foreign-income exemption: prior-three-year test, residence date and Exemption Certificate calendar
  • Qualified Service Centre (QSC/NHM) testing across group, country, related-party revenue and personnel conditions
  • Treaty article, residence certificate, beneficial ownership, withholding, credit and refund file by country and income type
  • Source, VAT, withholding and contract-tax consistency for service, licence/royalty, interest, dividend and financing flows
  • Transfer-pricing transaction inventory, functional analysis, method/comparables and period-specific reporting scope
  • Turkish tax model, outward-capital notification, annual investment survey and exit notification for foreign companies or branches
  • Foreign subsidiary/branch income, controlled foreign companies and profit-return options
  • Written question list, responsibility boundary and decision record for foreign-country counsel or tax advisers

Process

  1. 01

    Facts and flow map

    Map ownership, directors, decision-making, people, IP, bank, contracts, invoices and cash flows by jurisdiction.

  2. 02

    Turkish tax risk matrix

    Separate residence, PE, income type, treaty, VAT/withholding, transfer pricing and reporting duties with their legal basis.

  3. 03

    Foreign-country confirmation

    Send a written issue list to an authorised local professional; record foreign advice and assumptions separately.

  4. 04

    Implementation and calendar

    Turn the approved structure into contract-tax checks, registrations, filings, owners and deadlines.

Deliverables

  • Residence, PE, income/payment classification and taxing-right matrix
  • Turkish tax scenarios for alternative entity/branch and cash-flow structures
  • Country-and-income note showing the treaty article, domestic rate and required evidence
  • Transfer-pricing inventory, method/comparables actions and applicable reporting file
  • Turkish incorporation, registration, filing, outward-capital and foreign-investment reporting checklist
  • Decision, assumption, open-issue, owner and deadline register

Pricing model

Project scope depends on the jurisdictions, entities and people, transaction types, transfer-pricing work and need for foreign professionals. Ongoing filings and controls can use a monthly package; the foreign professional contracts and bills separately.

Typical timeline

The first risk map is scheduled after ownership, contracts, transactions and residence evidence are complete. There is no single fixed duration for foreign advice, incorporation, refunds or authority responses. Recurring reports and notifications follow a scope test for the relevant period.

Frequently asked

Do you have offices abroad?

No. My scope is Turkish tax, accounting and financial regulation. When foreign legal, incorporation or tax advice is needed, an authorised independent professional in that jurisdiction is identified separately, with written scope, authority, fees and responsibility. I do not promise a ready-made network in every country or provide foreign legal services under one engagement.

How many tax treaties does Türkiye have?

A static headline count is not used for a filing. Signed, in-force and effective treaties are different sets. Each case checks the Turkish Revenue Administration’s current treaty record, the relevant protocol and income article, beneficial ownership and residence-certificate evidence.

Is Türkiye’s 20-year “non-dom” exemption automatic?

No. Article 20/D depends on Turkish residence, the absence of Turkish domicile and tax liability in the prior three calendar years, foreign-source income and obtaining the Exemption Certificate within the deadline in Communiqué No. 333. Turkish-source income and corporate profits are analysed separately.

Do you incorporate my foreign company?

I plan the Turkish structure and tax scenario, outward-capital movement, accounting entries and mandatory Turkish notifications. Incorporation and legal work abroad are performed by an authorised local provider; jurisdiction choice is not based on the headline tax rate alone.

Is a transfer-pricing local file prepared every two years?

No. Türkiye’s corporate-tax return attachment, annual transfer-pricing report, master file and country-by-country obligations each have different scopes, thresholds and deadlines. The taxpayer and controlled transactions are tested for each accounting period; there is no general “every two years” rule.

Related guides and tools

Article 20/D: foreign-income exemption Separate the 20-year exemption’s prior-three-year, residence, Exemption Certificate and source conditions. Banking in Türkiye for foreign investors Align bank pre-clearance, beneficial ownership, document certification and source-of-funds evidence with the entry structure. Foreign-direct-investment notifications Manage E-TUYS and company/shareholding reporting for a foreign-owned Turkish entity. Liaison-office eligibility and setup Compare the non-commercial restriction, funding, payroll and conversion risk with other entry structures.

Official sources

Last statutory source check: 8 September 2026

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