Turkish Tax Opinion Services for Foreign Companies

Key facts: Turkish tax opinions at a glance

Who needs a Turkish tax opinion?

Most foreign companies that ask us for an opinion are not setting up in Turkey. They have one Turkish connection — a person, a customer, a contract or a payment — and someone (the board, the auditor, the buyer’s lawyers) wants the Turkish tax answer in writing.

If you are a law firm, a foreign CPA firm or an in-house tax team that needs Turkish input for your own client, see Turkish local tax counsel for international law and accounting firms.

What our Turkish tax opinions cover

Permanent establishment (PE) and corporate tax residence

Whether a non-resident company has a taxable presence in Turkey turns on the domestic definitions of a place of business (işyeri, Tax Procedure Law Art. 156) and a permanent representative (daimi temsilci, Art. 157), read together with Article 5 of the relevant treaty. Separately, a company whose place of effective management (iş merkezi) is in Turkey becomes a full Turkish taxpayer under Corporate Tax Law Art. 3. Our related deep-dives: does hiring a developer in Turkey create a PE and PE and corporate tax residency risk. For a team-wide assessment rather than a single question, use the remote workforce PE risk review.

Withholding tax on payments to and from Turkey

Turkish payers must withhold corporate tax on professional fees and royalties paid to non-residents (Corporate Tax Law Art. 30; 20% under Council of Ministers Decision 2009/14593), unless a treaty reduces or removes it. Classification decides the answer: business profits, professional services and royalties are taxed differently. See withholding tax and VAT on cross-border service payments.

VAT and reverse charge

Services performed in Turkey or used in Turkey are within Turkish VAT (VAT Law Art. 6/b). When the provider has no Turkish presence, the Turkish recipient self-assesses the VAT on return No. 2 (Art. 9). B2C digital services from abroad are handled through a separate simplified registration. See VAT registration for non-resident companies.

Tax treaty interpretation

Treaty rates, the 183-day services PE clauses found in many of Turkey’s treaties, beneficial ownership and the residence certificate requirements are covered in how to apply a Turkey tax treaty to a payment.

Digital services tax and other cross-border topics

Including digital services tax, intercompany service charges, transfer pricing support and the tax side of contracts with Turkish customers.

What you receive: anatomy of a Systems CPA tax opinion

Every opinion follows the same structure, so an auditor or a counterparty’s adviser can test it quickly.

Turkish tax opinion vs private ruling (özelge) vs legal opinion

Full comparison: Turkish tax opinion vs private tax ruling (özelge).

How the engagement works

1. Confidential enquiry. You send the company, countries involved, the transaction or arrangement, the contract (if any) and the tax question.
2. Scope and fixed-fee proposal. We confirm the questions in scope, the document list, the delivery date and the professional fee — in writing, before any work starts.
3. Technical review. We analyse Turkish legislation, the applicable treaty, published rulings (özelges) and court decisions against your documents, and come back with any fact gaps.
4. CPA-signed written opinion. You receive the opinion with legal basis, assumptions, conclusions, risks and recommended actions, plus a short call to walk your team or adviser through it.

We sell a defined written deliverable, not hours of meetings. Follow-up questions within the agreed scope are included.

What drives the cost of a Turkish tax opinion

We do not publish fees; each engagement is quoted at a fixed amount after scoping. What moves the quote:

• Number of questions and taxes. A single withholding question is narrower than a PE + VAT + payroll review.
• Treaty layer. Two-country questions are simpler than structures with a third-country holding or agent.
• Document volume. Contract sets, intercompany agreements and HR files take time to read properly.
• Settled vs open law. Where published özelges and court decisions are consistent, analysis is shorter; open questions (e.g. SaaS classification) need more.
• Audience. An opinion addressed to an auditor, lender or counterparty needs a reliance letter and tighter assumptions.
• Urgency. Signing deadlines can be met; they are scoped at the proposal stage.

How Turkey compares: getting tax certainty in other jurisdictions

The practical difference: in Turkey there is no paid, fast-track binding ruling. That is why foreign companies, and their auditors, rely on a written opinion from a licensed Turkish CPA — and file an özelge only for positions that will repeat for years.

Case analyses

What happens if…

What happens if we never get an opinion and the tax office finds a PE?

The tax office can assess Turkish corporate tax on profits attributable to the PE, plus a tax loss penalty equal to the tax (Tax Procedure Law Art. 344) and late-payment interest, along with unfiled VAT and payroll obligations. Five-year assessment periods apply.

What happens if the opinion turns out to be wrong?

The opinion does not bind the tax office. But a documented, well-reasoned position shows good faith, supports the penalty discussion and settlement (uzlaşma), and gives your auditor what it needs for an uncertain tax position file. The opinion states its assumptions so you know where the risk sits.

What happens if the facts change after the opinion?

The conclusion applies to the facts described. A new hire, new contract authority or a longer project can change the result — we list those triggers in the recommended actions section.

What happens if we need the tax office itself to confirm?

We draft and file a private ruling (özelge) request in Turkish on your behalf, framed on the same facts, and the opinion covers the period until the ruling is issued.

Frequently asked questions

Primary sources

1. Tax Procedure Law No. 213 (Vergi Usul Kanunu) — Arts. 114, 156, 157, 344, 369, 370, 371, 413
2. Corporate Tax Law No. 5520 (Kurumlar Vergisi Kanunu) — Arts. 3, 13, 30, 32, 35
3. VAT Law No. 3065 (Katma Değer Vergisi Kanunu) — Arts. 1, 6, 9
4. Law No. 3568 on Certified Public Accountants and Sworn-in CPAs
5. Turkish Revenue Administration (GİB) — legislation, treaties and published özelges
6. Official Gazette (Resmî Gazete) — Presidential Decisions on withholding rates

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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.