Скачать или смотреть Local and Global Minimum Supplementary Corporate Tax (ATV)

The General Communiqué on the Application of Local and Global Minimum Supplementary Corporate Tax has been published. This communiqué regulates the details of the local and global minimum supplementary corporate tax applied to multinational business groups, issued by the Ministry of Treasury and Finance in Türkiye. The regulation defines the procedures for calculating and applying the 15% minimum tax rate, which was introduced to prevent businesses from transferring profits to countries with low tax rates. The text details technical issues such as determining the tax base, exempted earnings, exempt entities, and transfer pricing adjustments. It also explains safe haven practices that can alleviate the tax burden on businesses and the methods to be followed in structural changes such as mergers or demergers. The document provides a framework consistent with OECD model rules aimed at ensuring tax fairness at both local and international levels. Finally, guidance is provided on how to assess deferred tax assets and prior year losses during the transition period.