test

Exemption for Business Offices and Permanent Establishments located
abroad
Following conditions are required in order to have corporate tax exemption for
corporate income obtained through business offices or permanent establishments
located abroad;
• According to the tax laws of the country, at least 15% of income and corporate
tax-related total tax burden,
• Transferring the profit of the relevant accounting period until the tax declaration
is due,
• If the principal activity of the participating company is finance, inclusive of financial
leasing, provision of insurance services or investment in securities, having
similar corporate tax rate with Turkey.
Participation Exemption
Following incomes are exempt from corporate income tax:
• The profits gained from the participation in the capital of another corporation
which holds fully liable taxpayer status,
• Dividends obtained from founding shares and other usufruct shares that enable
another institution subject to full tax liability to participate in profit,
• Profit shares of investment fund participation shares and venture capital investment
trusts which are subject to full taxpayer fund
• The participation shares of other funds and investment trusts and the dividends
from shares cannot be benefited from the participation exemption.
The regulation covers the dividends from shares obtained by the corporations only
by participating in the capital of the corporations subject to full taxpayer status.
There is no difference in applying the exemption whether the corporation receiving
the dividend is subject to full or limited taxpayer status.