NEWSLETTER-2021

325 TAX LAW the determination of corporate income. Although the rejection of the discount is clear in terms of the CTL, the situation in terms of VAT has been quite controversial. In order to resolve these discussions, regulations have been made under the framework of the VATL since 2016. Although these regulations remove the uncertainty on the subject, the situation is still controversial in terms of the period before the new regulations entered into force. Although there are opinions that do not accept the VAT deduction regarding the pre-regulation period, especially considering the will of the legislature regarding the new regulations, the better view is that disguised profit distribution through transfer pricing does not have any consequences in terms of VAT, and that the deduction of VAT declared and paid within this scope should also be accepted.

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