Turkish Local Tax Counsel for International Law and Accounting Firms
When your client has a Turkish tax question, you need a licensed local specialist who answers in your format, on your timeline, and stands behind the answer.
In one minute
- Built for professionals: we answer the Turkish question you scope, in English, in a format your client file can absorb.
- Independent: we do not compete for your client’s general mandate in their home country.
- Three models: independent opinion, co-sourced review, or Turkish input for your own deliverable.
- Conflicts checked and confidentiality agreed before any documents are shared.
Key facts
| Question | Answer |
|---|---|
| Who is the Turkish professional? | Evren Özmen, Certified Public Accountant licensed under Law No. 3568, TÜRMOB Reg. No. 35675. |
| Who is the client? | Either your firm (you engage us for your client) or your client directly — agreed at the start. |
| Language | English; Turkish or bilingual where a document must go to a Turkish authority. |
| Areas | Corporate tax, permanent establishment, withholding tax, VAT, tax treaties, transaction tax, payroll tax, transfer pricing support. |
| Not covered | Turkish legal opinions on corporate, contract or litigation matters — those require a Turkish lawyer; we work alongside your Turkish counsel. |
| Fees | Fixed per matter or agreed framework rates for repeat referrers — confirmed privately. |
Who we support
- International law firms advising on cross-border transactions, employment moves, distribution and licensing agreements, and disputes with a Turkish tax element.
- Foreign CPA and accounting firms whose clients hire in Turkey, sell to Turkish customers or receive Turkish payments, and who need a local position for their own advice or audit.
- In-house tax teams of multinationals that want an independent Turkish view before a decision, a filing or an audit discussion.
- Corporate service providers and M&A advisers who need Turkish tax diligence input. For partnership and network discussions, see international partnerships.
Three ways to work with us
| Model | What you get | Best when |
|---|---|---|
| 1. Independent Turkish tax opinion | A full, CPA-signed opinion addressed to you or your client (see the opinion service) | The client, a court, an auditor or a counterparty needs a separately signed Turkish view |
| 2. Co-sourced review | We review documents and model the Turkish position with your team; shared working papers; joint calls | Transactions, restructurings and diligence with tight timelines |
| 3. Turkish input for your deliverable | A Turkish tax memo you incorporate into your own advice, with our name and licence identified as the source of the Turkish analysis | Your firm owns the client relationship and the overall advice |
Who signs, who is responsible
Turkish tax advice is a regulated professional activity. Under Law No. 3568, accounting and tax advisory work in Turkey is reserved to licensed professionals, and the professional who signs carries the responsibility. So in every model:
- The Turkish analysis is prepared and signed by a licensed Turkish CPA, and the underlying signed memo stays on file.
- Where the Turkish section appears inside your deliverable, it identifies Systems CPA as the source of the Turkish analysis — we do not supply anonymous “ghost” opinions.
- Where a document must be certified by a sworn CPA (YMM) — for example for certain VAT refund files — we coordinate that certification and say so.
- Reliance, liability and confidentiality are set out in a short engagement letter before work starts.
Typical matters
| Matter | Turkish tax question |
|---|---|
| Employee relocation to Turkey | PE and dependent-agent risk, payroll withholding and social security, treaty residence |
| Distribution / licence agreement | Withholding on royalties vs business profits, VAT reverse charge, stamp duty on the contract |
| Share sale involving a Turkish company | Tax on the gain for a non-resident seller, treaty allocation, filing mechanics |
| Intercompany service charges | Deductibility, withholding, VAT and transfer pricing documentation |
| Dispute or tax audit | Technical position paper, settlement (uzlaşma) strategy support, co-working with Turkish litigation counsel |
| Market entry without an entity | Serving Turkish customers: VAT, PE and contractor status |
How a referral runs
- Conflict check and NDA. Names of parties first; we confirm no conflict before seeing documents.
- Scope note. You send the question as you want it answered; we return the scope, document list, delivery date and fixed fee.
- Work in your format. Memo, opinion, comment layer on your draft, or a section for your report — and calls with you or the client as agreed.
- Delivery and stand-by. Signed Turkish analysis delivered; follow-up questions within scope included until the matter closes.
What drives the cost
- Model chosen (input memo, co-sourced review or full opinion)
- Number of Turkish taxes and treaty layers involved
- Document volume and language (Turkish source documents need review in the original)
- Reliance requested by third parties
- Timeline — transaction deadlines are scoped up front
Repeat referrers can agree framework terms so each new matter starts with a one-page scope note. We do not publish fees.
Local counsel models compared
| Option | Strength | Limitation |
|---|---|---|
| Big-4 member firm in Turkey | Brand and network depth | Independence conflicts with audit relationships; higher cost structure; network referral routing |
| Turkish law firm | Litigation and legal opinions | Tax computation, VAT mechanics and filings usually sit with accountants |
| Independent Turkish CPA (Systems CPA) | Direct access to the signing CPA, English drafting, fast scoping, no competing home-country mandate | Turkish legal opinions require a Turkish lawyer — we work alongside one |
| Answering from your own team | Lowest cost | No Turkish licence, no local practice knowledge of özelges and tax office behaviour |
Case analyses
- Facts
- A law firm advising a European buyer needed the Turkish tax position on a non-resident seller’s gain and on historical intercompany charges of the Turkish target, within a two-week signing window.
- The obvious answer
- “The treaty gives taxing rights to the seller’s state, so Turkish tax is not our problem.”
- Why that was not enough
- The treaty question was only half of it: the target’s own historical exposures (undocumented management fees, missing reverse-charge VAT) sat inside the company the buyer was acquiring.
- Structure adopted
- A co-sourced review: a short Turkish memo on the seller-side gain for the law firm’s SPA drafting, and a list of quantified target exposures that went into the tax indemnity and price discussion.
- Facts
- A European accounting firm’s client hired two engineers in Turkey through a contractor model and the firm wanted to cover the Turkish angle in its own year-end advice.
- The obvious answer
- “Contractors, so no employment and no PE.”
- Why that failed
- Exclusivity, fixed hours and integration into the client’s team pointed towards disguised employment and potential PE exposure.
- Structure adopted
- A Turkish input memo identified as Systems CPA analysis, incorporated in the firm’s advice, recommending an employer-of-record bridge and a decision point for a Turkish entity (see EOR vs own entity).
What happens if…
What happens if our client wants to contact you directly?
Only if you agree. The engagement letter sets who the client is and who communicates with whom; we do not solicit your client for other work.
What happens if the Turkish answer conflicts with the advice we already gave?
We tell you first, privately, with the reasoning and the sources, so you can decide how to address it with your client.
What happens if a Turkish legal opinion is also needed?
We coordinate with your Turkish law firm, or introduce one, and keep tax and legal sections consistent.
Frequently asked questions
Can a foreign law firm engage a Turkish CPA for its client's tax question?
Yes. The law firm can engage Systems CPA directly for its client’s matter, or the client can engage us; who the client is, reliance and confidentiality are set out in a short engagement letter.
Do you provide white-label Turkish tax opinions?
We provide Turkish tax input that you can incorporate into your own advice, but the Turkish analysis is always identified as prepared and signed by a licensed Turkish CPA. We do not supply anonymous opinions.
Who is responsible for the Turkish tax analysis?
The licensed Turkish CPA who signs it — Evren Özmen, TÜRMOB Reg. No. 35675 — under Law No. 3568.
Do you give Turkish legal opinions?
No. Turkish legal opinions on corporate, contract or litigation matters must come from a Turkish lawyer. We work alongside your Turkish counsel on the tax side.
Do you compete with the referring firm for the client?
No. We do not solicit the referred client for work outside the Turkish matter and communicate with the client only as agreed with you.
Can repeat referrers agree standard terms?
Yes. Framework terms let each new matter start with a one-page scope note; fees are confirmed privately.
Need Turkish tax input for a client matter?
Send the parties’ names for a conflict check and a one-paragraph description of the question. We reply with scope, timing and a fixed fee — confirmed privately.
WhatsApp a Turkish CPA Email info@ozmconsultancy.com Request a proposalPrimary sources
- Law No. 3568 on Certified Public Accountants and Sworn-in CPAs
- Tax Procedure Law No. 213 (Vergi Usul Kanunu) — Arts. 114, 156, 157, 344, 369, 370, 371, 413
- Corporate Tax Law No. 5520 (Kurumlar Vergisi Kanunu) — Arts. 3, 13, 30, 32, 35
- VAT Law No. 3065 (Katma Değer Vergisi Kanunu) — Arts. 1, 6, 9
- Attorneys Act No. 1136 (Avukatlık Kanunu)
- Turkish Revenue Administration (GİB) — legislation, treaties and published özelges
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This page is general information on Turkish tax law as in force in October 2026. It is not a tax opinion and does not create an engagement. A written opinion is issued only after a fixed-scope engagement, on the specific facts and documents provided, and states its own assumptions and limitations.
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