Tax Law

In our work in this field, the provisions of the Tax Procedure Law No. 213, the Code of Administrative Procedure No. 2577, the Law No. 6183 on the Procedure for the Collection of Public Receivables, and the relevant tax legislation are taken into consideration. Each dispute is addressed by jointly evaluating the nature of the document served, the applicable time limits, the grounds underlying the authority's act, and the particular features of the specific case.

Within the scope of tax law, we provide legal support in matters concerning the protection of the taxpayer's rights during the tax audit process, the assessment of audit reports and tax inspection reports, and the examination of pre-assessment and post-assessment settlement opportunities.

In disputes arising from tax and penalty assessment notices, tax-loss penalties, irregularity and special irregularity penalties, late-payment interest, late-payment surcharges, and tax-base differences, the administrative and judicial remedies available to the taxpayer are evaluated on the basis of the specific documents and time limits.

Correction and complaint applications, settlement applications, requests for the reduction of penalties, and actions to be brought before the tax courts against acts established by the tax authority are also within our field of practice. In these processes, the accurate monitoring of application and litigation time limits is of great importance in terms of avoiding any loss of rights.

Furthermore, we evaluate the taxpayer's legal position with respect to payment orders, attachment proceedings, electronic attachment practices, requests for security, precautionary attachment, and other administrative acts at the collection stage; and we pursue the application and litigation remedies appropriate to the specific case.

Among the disputes most frequently encountered in practice in tax law are tax assessments made as a result of a tax audit, tax-loss penalties, special irregularity penalties, allegations of false or misleading documents, tax-base differences, and acts relating to taxpayer registration records.

In such disputes, not only the assessment notice or the payment order, but also the tax inspection report, the underlying records, the books and documents, the invoice records, the bank transactions, the documents evidencing the commercial relationship, and the grounds underlying the authority's act must be examined together. In order for tax disputes to be soundly evaluated, the factual circumstances and the tax characterization must be addressed jointly.

At the collection stage, objections to payment orders, the lifting of attachment proceedings, whether the debt has become time-barred, whether the payment order has been duly served, and whether the public receivable has been lawfully pursued are among the matters frequently raised.

Since time limits in tax disputes are particularly short and strict, the accurate determination of the date of service and the prompt evaluation of the course to be followed are important in terms of preventing any loss of rights.

The tax law process begins, first and foremost, with the examination of the tax and penalty assessment notice, the tax inspection report, the payment order, the attachment notice, or the relevant administrative act document served on the taxpayer. On the basis of these documents, the grounds for the act, the date of service, the application period, the period for bringing an action, and the available legal remedies are evaluated.

Depending on the nature of the dispute, administrative resolution options are addressed first. Whether settlement, a correction request, a complaint application, a reduction in the penalty, or another relevant administrative application remedy is appropriate for the specific case is evaluated. At this stage, it is important that applications be made within the statutory time limits and on the correct legal grounds.

Where administrative remedies yield no result, are not appropriate, or where the direct filing of an action is necessary, an action is brought before the tax court. Where necessary, a stay of execution is requested, and throughout the proceedings the petitions, evidence, interlocutory decisions, and court actions are monitored.

In each case, the aim is to evaluate the taxpayer's legal position realistically, to determine whether the administrative act contains any unlawfulness, and to conduct the process in a manner that is compliant with the legislation, careful, and that does not give rise to any loss of rights. The client is regularly informed about the stages of the process, the possible risks, and the legal remedies that may be pursued.