What is the status of the payments made in return for the purchase of services such as finding customers and marketing from limited taxpayer institutions regarding the goods and services exported abroad?
If the activity of the company abroad, which provides services in relation to the goods and services exported abroad, consists of finding customers and receiving a commission on the price of the goods sold, this business will be evaluated within the framework of commercial activity and no tax deduction will be made pursuant to Article 30 of the Corporate Tax Law No. 5520.
However, if the activity in question is foreign market research, advertising the products, services such as marketing and management services and exceeds the mere brokerage service, they will be considered as self-employment services and in accordance with Article 30/1-b of the Corporate Tax Law, a 20% corporate tax deduction will be required in accordance with the Council of Ministers Decision No. 2009/14593.
On the other hand, the provisions of the double taxation agreements regarding self-employment activities will be primarily considered.
Source: Revenue Administration of Turkey – Translated by: Karen Audit
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