Tax disputes in Turkey can be resolved through pre-assessment settlement, post-assessment settlement, or tax court litigation. Foreign companies should evaluate options carefully.
Settlement Options
Pre-assessment: izaha davet (invitation to explain).
Post-assessment: uzlaşma (settlement) at tax administration.
Voluntary disclosure with reduced penalties.
Litigation
Tax court of first instance: 30-day deadline from assessment.
Regional Administrative Court appeal.
Council of State (Danıştay) for cassation.
Specific Issues
Transfer pricing disputes increasingly common.
Permanent establishment determinations.
VAT refund denials.
Frequently Asked Questions
What is izaha davet?
Pre-assessment opportunity to explain transactions and avoid penalties.
How long does tax litigation take?
Typically 2-4 years through full appeal cycle.