Our Double Tax Treaty Services

Permanent Establishments

There are not specific rules for presence of permanent establishment in Turkish tax legislation, as in many countries, and there are uncertainties in this respect.

Centrum Consulting expertise in permanent establishments includes the following:
  • Identifying if activities in Turkey or related countries constitute a PE,
  • Determining if activities in Turkey or related countries are within the PE exemption,
  • Analysing if activities conducted through commissionaire in Turkey or related countries constitute a PE,
  • Evaluating whether the persons carrying activities in Turkey or related country on behalf of the company constitute a dependent agent,
  • Determining the PE risk and attributable profit to PE,
  • Determining if economic activities in digital/electronic form in Turkey or related countries constitute a PE.

Intangibles and Royalty Payments

Centrum Consulting offers special services in terms of intangibles and royalty payments regulated under the double tax treaties;
  • Examining the nature of the related transaction and assessing whether it is within definition of royalty,
  • Determining if there is any intangible asset in the transaction,
  • Identifying which provision of the double tax treaty is applicable as it is considered that there is no intangible asset in the concerned transaction.

Dependent Personal Services and Remuneration

Employees of multinational companies in some cases face taxation problems in the country they work on a temporary or permanent basis.

There might be uncertainties about the country of taxation on remuneration, salary and other benefits of employees resident in Turkey or a foreign country. We are ready to answer all your questions. Centrum Consulting's expertise in this field will add value for both your company and personnel. FATCA and Common Reporting Standard

OECD countries will be realizing automatic exchange of information in financial issues based on "Common Reporting Standard (CRS)" as from 2017. This also includes automatic exchange of financial accounts between countries. Besides, Turkey has also signed "Foreign Account Tax Compliance Act (FATCA)" with US within the scope of bilateral agreement.

Automatic exchange of information (CRS and FATCA) imposes serious liabilities on financial institutions such as banks as well as tax authorities.

We are of the opinion that our CRS and FATCA consulting services will provide significant value to your company. Our CRS and FATCA services include:
  • Determining your institution's CRS and FATCA liabilities,
  • Assessing the impact of CRS and FATCA on your institution's activities
  • Demonstrating differences between CRS and FATCA
  • Planning your institution's compliance with CRS and FATCA requirements
  • Supporting your intra-organization operations and infrastructure preparations for CRS and FATCA
  • Offering alternative solutions to your institution about CRS and FATCA practices.

Prevention Double Taxation and Mutual Agreement Procedure

As Centrum Consulting, we continue supporting you also in this process with our experience of long years in MAP. Our consulting services for your company and/or group company in terms of MAP applications include;
  • Evaluating if the concerned transaction leads to double taxation,
  • Searching for alternative ways to application for MAP,
  • Preparing information and documentation required by the legislation,
  • Executing communications with tax authorities for MAP,
  • Preparing information and documentation additionally required by tax authorities, and
  • Evaluating and providing opinions on the resolution offered to your company in case both tax authorities reach an agreement during the MAP process.

Our Other International Tax Services

In addition to others, our expertise on international tax also contains;
  • Interest and dividends,
  • Income from shipping, air and land transport,
  • Capital gains
  • Independent services
  • Director's fee
  • Payments to artists and athletes
  • Pension, annuities and social security pensions
  • Other income