Bringing Clarity to International Taxation: Focused on OECD Pillar 2 and Double Taxation Agreements
Sworn-in CPA & Tax Partner with 15+ Years of Trusted Expertise
I am Sworn-in CPA and Tax Partner at a consulting firm specializing in tax audit, certification, and advisory services. With extensive experience in tax compliance and risk management, my expertise covers Double Taxation Agreements (DTAs) and the implementation of OECD’s Pillar 2 framework. I support organizations in navigating complex international tax challenges, ensuring compliance and optimizing tax strategies within the evolving Turkish tax landscape.
OECD Pillar 2 Implementation in Turkey
Turkey has implemented the GloBE rules, including QDMTT, IIR and UTPR, requiring large multinational groups to meet a 15% minimum effective tax rate. Companies operating in Turkey must evaluate their Pillar Two exposure, calculate potential top-up taxes, and ensure timely compliance with local reporting obligations.
Effective Tax Rate Calculation
Filing & Documentation
complıance and advısory servıces
Comprehensive support across key areas
Tax Certification
Corporate tax filings, VAT refund claims, and other certifications handled with full compliance and precision.
Tax Advisory
Guidance on tax planning, compliance, and optimization for corporate tax, VAT, and other regulatory requirements.
Tax Treaties
Guidance on interpreting tax treaties, leveraging treaty benefits while managing cross-border tax risks.
OECD Pillar II
Advisory on QDMTT and UTPR compliance, identifying Pillar 2 exposures and optimizing effective tax rates.
Insights & Articles
Corporate Tax Withholding on Overseas Software Payments
Guidance on the correct corporate tax treatment of payments for software purchased from overseas companies, covering commercial income, royalties, capital gains, and self-employment income, in line with Turkish tax law, OECD Model Convention, and double taxation agreements.
Management and IT Fee: Tax and Accounting Guidance
Comprehensive overview of the tax and accounting treatment of management and IT fees issued by foreign headquarters to Turkish subsidiaries. Covers VAT, corporate tax, accrual principles, withholding obligations, and considerations for compliance and proper expense recognition.
Branch Remittance Tax: Taxation of Profit Transfers From PE to Head Office
This article explains the application of branch remittance tax in Turkey, its classification as an additional tax on business profits, and the role of double tax treaties in limiting or eliminating withholding on profit transfers to head offices.
Digital Service Tax in Turkey: Scope, Thresholds and Rate
Turkey’s Digital Service Tax targets large digital businesses providing advertising, content, or platform services to Turkish users. This article explains the scope, revenue thresholds, and tax rate in a clear and practical way.
QDMTT Return for Financial Year 2024 in Turkey
Guidance on the Qualified Domestic Minimum Top-up Tax (QDMTT) for fiscal year 2024 in Turkey, covering filing requirements, calculation of effective tax rate, and the computation of top-up tax for Turkish entities within multinational groups.
Deferred Tax Adjustments for QDMTT Purposes
Deferred tax adjustments for QDMTT purposes, covering valuation allowances, accounting recognition adjustments, recognition of domestic tax losses, and their impact on the effective tax rate under Pillar Two and the Turkish Corporate Tax Code.
The Importance of Qualified CbCR and Inflation Adjustment
Guidance on the Transitional Safe Harbour under Pillar Two, focusing on the qualification of CbCRs, the use of qualified financial statements, and the impact of inflation adjustment differences between tax accounting records and TFRS on effective tax rate calculations.
UTPR under Pillar Two and Transitional Relief in Turkey
An overview of the Undertaxed Profits Rule (UTPR) in Turkey, focusing on the one-year deferral starting from 2025, the transitional UTPR relief mechanism for early-stage multinational groups, and potential mitigating effects on global top-up tax exposure under Pillar Two Implementations.