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Country Note: Analysis of Turkey’s Controlled Foreign Company Regime

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Country Note: Analysis of Turkey’s Controlled Foreign Company Regime


Intertax
Volume 50, Issue 5 (2022) pp. 466 – 475

https://doi.org/10.54648/taxi2022041



Abstract

This study analyses Turkey’s current position against the policies it has carried out, especially regarding the controlled foreign companies (CFC) taxation regime by the Organization for Economic Cooperation and Development (OECD). As a member of the OECD and G20 during both the preparation and processing of the OECD’s Base Erosion and Profit Shifting (BEPS) Project, Turkey has undertaken various roles. Nevertheless, it is observed that existing CFC rules and current developments regarding Turkey’s CFC regime fall below the minimum standards recommended in the BEPS Action 3 Final Report, and there is a certain ‘resistance’ that continues to regulate some matters. This study seeks to critically analyse and display Turkey’s position for coping with the BEPS Action Plan concerning CFC regulations.


Keywords

Controlled Foreign Company (CFC), Base Erosion and Profit Shifting (BEPS), Turkish Corporate Income Taxation, International Taxation Principles, Tax Avoidance.


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