Turkey: Rights to taxation under income tax treaties | KPMG | GLOBAL
Share with your friends

Turkey: Rights to taxation under network of income tax treaties

Turkey: Rights to taxation under income tax treaties

Guidance published in the official gazette in late September 2017 concerns Turkey’s network of income tax treaties for the avoidance of double taxation and includes explanations regarding the tax rules with respect to individuals or enterprises that are residents of a treaty-contracting country, income from professional services, and other activities of an “independent character” in Turkey.


Related content

The ability of a treaty partner-country to tax income derived from professional service income derived by individuals and enterprises generally is subject to Article 14 “Independent professional services” of Turkey’s income tax treaties and to Article 5 “Permanent establishment” and Article 7 “Business income” of the treaties. In some treaties, provisions regarding these articles may be subject to additional rules contained in Protocols to the treaty.

The September 2017 guidance (referred to as a “communiqué”) clarifies measures that require attention on determining the taxing right of Turkey with respect to professional service income of non-residents, or the taxation of such income in accordance with the provisions of domestic legislation. There are also measures that address required documentation and the refund mechanism for taxes that were collected and were subject to a refund claim. 


Read a September 2017 report [PDF 281 KB] prepared by the KPMG member firm in Turkey

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal