Publications
Primetax Insights
Stay informed with our analysis of legislative developments, practical guidance and selected publications.
- Guides
Primetax Guide: Cash Pooling in Türkiye
This guide outlines the principal Turkish legal, foreign-exchange and tax considerations for corporate groups that include a Turkish company in a cash pooling arrangement. It focuses on the issues that should be reviewed before a Turkish entity is connected to a physical, notional or multi-currency pool, including cross-border loan restrictions, transfer pricing, thin capitalisation, withholding tax, VAT, stamp tax and the Resource Utilisation Support Fund (RUSF).
- Guides
Primetax Guide: Controlled Foreign Corporation (CFC) Regime in Türkiye
This guide explains when profits of a foreign subsidiary may be taxed in Türkiye before they are distributed to its Turkish owners. It covers the control, passive-income, low-tax and revenue tests under Article 7 of Corporate Tax Law No. 5520, together with the timing of inclusion, foreign tax credits, later profit distributions, Turkish-resident individual shareholders and the interaction with Türkiye’s global minimum tax rules.
- Guides
Primetax Guide: What Constitues a "Qualifying Foreign Credit Institution" in Türkiye?
This guide explains how the status of a foreign lender affects the Turkish tax treatment of cross-border financing. It focuses on the criteria used for interest withholding tax, VAT and stamp tax, the evidence commonly required to support foreign credit-institution status, and the particular risks arising where the lender is a group treasury company or another related party.
- Guides
Primetax Guide: Ultimate Beneficial Ownership (UBO) in Türkiye
This guide explains how ultimate beneficial owners are identified and reported in Türkiye, who is subject to the reporting obligation, when updates are required, and how the tax-reporting rules interact with separate anti-money-laundering customer due-diligence requirements. It also highlights the 2026 penalty framework and practical steps for maintaining defensible UBO records in multi-tier ownership structures.
- Guides
Primetax Guide: International Holding Companies in Türkiye
This guide outlines the current Turkish tax framework for using a Turkish company as an international holding vehicle. It explains the two alternative foreign-dividend exemption routes available in 2026, the special exemption for disposals of foreign participations, outbound dividend withholding, the domestic minimum corporate tax and the main structuring points that should be tested before establishing or reorganising a holding platform in Türkiye.