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1、Taxation & Investment in TurkeyNexia International Tax Conference Istanbul 1 June 02, 2011,The information included herein is not intended or written to be used, and it cannot be used by any taxpayer.The information included herein is of a general nature and should not be relied on as tax advice. Co
2、nsultation with a tax advisor in respect of specific transactions should be undertaken.,Main Taxes Income Taxes Taxes on Transactions of G&S Other Taxes Inbound Investment to Turkey Liability to Tax Financing & Thin Capitalization Transfer Pricing CFS Exemption Payments to the Non Residents Main Inc
3、entives New Trade Law,Outline,3,Income Tax Corporate Income Tax Personal Income Tax Tax on transfer of G&S VAT Real Estate Transfer Tax Special Consumption Tax (petrolium products, motor vehicles, tobacco products, luxery goods) Special Communication Tax Inheritance and Gift Tax Other Taxes Bank and
4、 Insurance Transactions Tax Stamp Duty Property Tax Motor Vehicle Tax,MainTaxes,4,Corporate Income Tax Taxable Entity,Unlimited Taxpayer Status Taxed on WWI Resident Entities JSC LLC other corporations and legal entities Foreign Subsidiaries (with legal base in Turkey) Non-Resident Entities Main Bus
5、iness Center is in Turkey Same rules apply both domestic and foreign Unlimited Taxpayers Limited Taxpayer Status Taxed on income and gain derived in Turkey Taxation depends on the type of the income and DTT Business income derived from a premises-offices or by an representative The same rules apply
6、with Unlimited Taxpayer (except WWI) Liaison Offices No tax requirement, if doing no business activity No Consolidation,5,CIT (Unlimited Taxpayer),Financial Year Calendar year, or Other 12 months period (upon taxpayers request and approval of Tax Administiration)Returns & Payment Quarterly Advance C
7、IT Return (second month) CIT Return (4th month)(*) Apply to Limited Taxpayers with business or agricultural activities,6,CIT Base: Adjusted corporate income,Business Income Adjusted for Tax Purposes; Deductables Dividend income from unlimited taxpayers to unlimited taxpayer Dividend income and capit
8、al gain from CFS Income from sale of real property and subscription stocks, held more than 2 years (75%) Unrealized gains from financial assets Incentives and other deductions Losses carried forward 5 year No loss carry back Undeductebles Unrealized losses of securities Penalties Personal expenses D
9、onations over certain limits,7,PERSONAL INCOME TAX,Personal Income Tax-1,Taxable Person - Individuals incurring taxable income Residents worldwide income Non-residents Income derived from Turkey Residence test (183 days rule) Be determined in line with applicable DTT Tax Base: Income from, Trade and
10、 business activities Agriculture Independent professional service Immovable assets and rights Income from capital investment (dividends, interests, etc.) Wages and salaries Other incomes(*) Exemptions, deductions and personel allowances apply,9,Personal Income Tax-2,Period: Calendar year Returns & P
11、ayment Quarterly Advance Tax Return (income from business activities and professional service) No filing requirement in certain cases (mostly WHT case, salary only from one employer, etc.) Tax Rates Progressive tax rates,10,Income (TRY),Tax Rate (%),0 - 9.4009.401 - 23.000 23.001 - 53.000 53.000 - ,
12、15 20 27 35,Personal Income Tax Rate,(*) Lower for wages (*) If allowade not to fill tax return, lower rates or WHT apply (Euro/TRY = 2,2),11,(2011),Taxable income is calculated in accordance with the Turkish Accounting Standards issued by Ministry of Finance Accural basis (except income from profes
13、sional service and rents) Depreciation: Straight-line or Accelerated method. Usefull life is anounced bu Tax Administration (from 2 to 50 years, generally 5 year) Inflation accounting for high inflation periods (once)Dividends treated as flow through entities until to individuals or foreigners. Inte
14、rest paid to related or unrelated parties is deductible. TP and Thin Capitalization rules apply,Provisions for Income Taxes,12,VALUE ADDED TAX,Value Added Tax,Credit mechanism Paid VAT = Collected Input Refund in some cases for residual (exemption, etc.) Monthly VAT Return VAT Rates Generaly 18 % Ba
15、sic foods, medicines, book, textile, meals, etc. 8 % Dried food, cotton, newspaper, etc. 1 %,14,VAT - Taxable Transactions,G&S transactions (except personel assets) Import of G&S Main exemptions Export (and free zones) Transit transportation Temporary import of goods (transit), free-zones Diplomatic
16、 exemption Services of banks, insurance companies Suplies to taxpayers with Investment Incentive Certificate Certain suplies and services for cultural, educational, social, miltary purposes Other sectoral exemption (sea, air, railway transportation, petrolium extract, defence, precious metals and st
17、ones,15,Main Taxe Rates,Income Tax Corporate Income Tax (20%) Personal Income Tax (%15 35%) Tax on transfer of G&S VAT (18% - 8% - 1% - exemptions) Real Estate Transfer Tax (0,15% + 0,15%) Special Consumption Tax (0% - 84%) (petrolium products, motor vehicles, tobacco products, luxery goods, etc. Special Communication Tax (5% - 25 %) Tax on Inheritance (1% - 10%) and Gift (10% - 30%) Other Taxes Bank and Insurance Transactions Tax (5%) Stamp Duty (from fixed amount to 0,825 %) ceiling TRY1.251.383,40 Property Tax (0,1% - 0,3%) Motor Vehicle Tax Etc.,
