TAX OF LAW
This book, which was written and has been published as a collection of published articles by Ersin Nazalı in various journals on the basis of the basic principles of tax law, has taken a pioneering role in its field.
In this book, which facilitates access to the articles published at different times and in different publications, articles on specific topics written by Ersin Nazalı for more than ten years, are classified.
BASIC PRINCIPLES AND CONCEPTS OF TAX LAW
1.1 APPLICATION OF TAX LAWS FROM SPACE 17
1.1.1 General description 17
1.1.2 Actual application of tax laws 17
1.1.3 IMPLEMENTATION OF TAX LAWS AND ENCOURAGEMENT COMPETENCES IN TAXATION 19
1.1.4 Prevention of double taxation with unilateral regulations in internal law 20
1.1.4.1 Offset Method 20
1.1.4.2 Exception Method 21
1.1.4.3 Expenditure Method 21
1.1.5 Prevention of Double Taxation with International Agreements 22
1.1.5.1 Prevention of Double Taxation by Participating in International Economic Integration 23
1.1.6 Other Country Practices on Double Taxation Prevention 24
1.1.6.1 France 24
1.1.6.2 UK 24
1.1.6.3 Russia 24
1.1.6.4 Germany 24
1.1.7 Result 25
1.1.8 References 25
1.2 TIMELY IMPLEMENTATION OF TAX LAW 27
1.2.1 INTRODUCTION 27
1.2.2 General description 27
1.2.3 Implementation of tax laws in time 28
1.2.3.1 Entering Tax Procedures 28
1.2.3.2 Removal of the Tax Code 29
1.2.4 Backward and Forward Walk of Tax Code 30
1.2.5 Other Country Practices on Time-Enforcement of Tax Procedures 33
1.2.6 Decisions of Higher Judicial Organs on Time-Enforcement of Tax Procedures 35
1.2.7 Result 36
1.2.8 References 37
1.3 TAX LAW-PRIVATE LAW RELATIONSHIP AND IMPLEMENTATION OF THE PRIMARY ECONOMIC APPROACH TO THE VUK
1.3.1 INTRODUCTION 38
1.3.2 TAX LAW-PRIVATE LAW RELATIONSHIP 38
1.3.3 PRINCIPLES OF ECONOMIC APPROACH 39
1.3.4 SOME POSITIONS THAT HAVE BEEN INSTALLED FOR THE PRINCIPLE OF THE ECONOMIC APPROACH 41
1.3.4.1 Tax-Veiling 41
1.3.4.2 Contracts Amending Tax Liability and Responsibility 42
1.3.4.3 Collusion 43
1.3.4.4 CONCLUSION 44
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2.1 THE LEGAL QUALITY OF THE CIRCULARS (WHAT DOES THE CIRCULARS NOT MEAN?) 45
2.1.1 INTRODUCTION 45
2.1.2 RESOURCE AUTHORITY AND QUALIFICATION 45
2.1.3 LEGAL REGULATION REQUIREMENTS 46
2.1.4 REGULATORY PROCEDURES BY THE MINISTRY OF FINANCE 47
2.1.5 LEGAL QUALITY OF CIRCULARS 48
2.1.6 PROBLEMS THAT APPEAR
2.1.7 RESULTS 53
2.2 WHAT IS THE REAL ESTATE INVESTMENT PARTNERSHIP OF THE CORPORATE TAX LAW (KVK)? 54
2.2.1 INTRODUCTION 54
2.2.2 REGULATIONS REGARDING THE REAL ESTATE INVESTMENT COMPANY ESTABLISHING EARNINGS 54
2.2.2.1 Exceptional Clause in the Corporation Tax Act: 54
2.2.2.2 Real Estate Investment Trusts in Capital Markets Legislation: 56
2.2.2.2.1 Provisions of the Capital Markets Law on Subject 56
2.2.2.2.2 Capital Markets Board Regulations on Topics: 59
2.2.2.2.3 Draft Proposal of Capital Markets Board for Real Estate Investment Trusts: 61
2.2.2.2.4 Capital Markets Board Investor Information Booklet Published by the Capital Markets Board in relation to the Subject: Explanations on Real Estate Investment Trust in 5 Publications: 62
2.2.2.3 What do real estate investment partners do? 62
2.2.2.4 What is the economic contribution of real estate investment trusts? 63
2.2.2.5 What advantages do real estate investment partners offer to investors? 63
2.2.3 FOREIGN COUNTRY EXAMINATIONS FOR REAL ESTATE INVESTMENT PARTNERS 63
2.2.4 EVALUATION 64
2.2.5 CONCLUSION 69
2.2.6 References 69
2.3 PROPERTY RIGHTS AND TAXATION 70
2.3.1 INTRODUCTION 70
2.3.2 FUNDAMENTAL RIGHTS AND FREEDOMS 70
2.3.3 PROPRIETARY RIGHTS 71
2.3.3.1 Property right in the Constitution 72
2.3.3.2 Limitation of the right of ownership 72
2.3.3.3 Suspension of ownership 73
2.3.4 TAXATION COMPETENCE 74
2.3.4.1 The history of taxation authority 74
2.3.4.2 Taxation authority in the Constitution 75
2.3.4.3 Constitutional principles of taxation 76
2.3.4.4 Taxation in the state of law 77
2.3.4.5 Social State and Taxation 79
2.3.4.6 Intervention to the right to property by taxation 81
2.3.5 PROPRIETARY RIGHTS AND TAXATION IN THE CONTEXT OF THE EUROPEAN HUMAN RIGHTS AGREEMENT 82
2.3.5.1 Scope of Ownership 82
2.3.5.2 Limitation on the right to property 84
2.3.5.2.1 Legality 84
2.3.5.2.2 General utility 86
2.3.5.2.3 Proportionality 86
2.3.6 Human rights The European Court's approach to property rights in terms of Taxes 88
2.3.7 CONCLUSION 95
2.3.8 REFERENCES 96
3.1 THE LEGAL QUALITY AND REFLECTION OF TAX LAW 98
3.1.1 INTRODUCTION 98
3.1.2 ADMINISTRATIVE CASES 100
3.1.2.1 Cancellation Case 101
3.1.2.2 Full judicial cases 102
3.1.3 VISIBILITY RELATED TO THE QUALIFICATION OF TAX LAW 103
3.1.3.1 Observation in the Doctrine 104
3.1.3.1.1 Tax Case is a Full Judicial Case 104
3.1.3.1.2 The Tax Case is a Action for Nutility 104
3.1.3.1.3 One of a kind Case 105
3.1.3.1.4 Tax case is a mixed case 106
3.1.3.1.5 The opinion of the Council of State on the nature of the tax action 106
3.1.3.1.6 Opinion 108
3.1.4 Significance of the nature of the tax claim 109
3.1.5 CONCLUSION 114
3.2 VISITS TO RESOLVE TAUGHT DISPUTES IN TURKEY ON JUDICIAL STUDY 115
3.2.1 INTRODUCTION 115
3.2.2 General description 116
3.2.3 The Ottoman period 116
3.2.4 The Process of the Tax Judge in the Republican Period 118
3.2.4.1 Pre-1980 Period 118
3.2.4.1.1 The Emergence of Tax Disputes 119
3.2.4.1.2 Tax Appeal Commissions 119
3.2.4.1.2.1 Major Tax Appeals Committees 120
3.2.4.1.2.2 Compliant Tax Appeal Commissions 120
3.2.4.1.2.3 Application to Objection Commissions 120
3.2.4.1.3 Taxes The appeal commission 120
3.2.4.1.4 The Council of State 121
3.2.4.1.5 Settlement of disputes relating to taxation not subject to the Tax Procedural Code 122
3.2.4.1.6 Application to the Judicial Organs 122
3.2.4.2 Evaluation of the Pre-1980 Period 122
3.2.4.3 Turkish tax judicial system after 1980 124
3.2.4.3.1 Tax Courts 125
3.2.4.3.1.1 Opening the Tax Case 126
3.2.4.3.1.1.1 Duration of Opening 126
3.2.4.3.1.2 Procedure
3.2.4.3.2 Tax Appeals on Tax Disputes 130
3.2.4.3.2.1 Tax Disputes to be Treated by the Taxpayer and the Council of State 130
3.2.4.3.2.1.1 The ones who are authorized to file lawsuits in the Court 130
3.2.5 Result 132
3.2.6 References 132
3.3 DIRECT INDIVIDUAL APPLICATION FOR TAX CONSIDERATIONS OF THE CONSTITUTIONAL COUNCIL 134
3.3.1 INTRODUCTION 134
3.3.2 REGULATION ON INDIVIDUAL APPLICATION 135
3.3.2.1 Constitution 135
3.3.2.2 Law No. 6216
3.3.3 THE POSSIBLE READING STANDARDS BASED ON THE CONSTITUTIONAL COURT 137
3.3.3.1 Property in the Constitution and Restriction 137
3.3.3.2 Authorization and Principles of Taxation in the Constitution 139
3.3.3.3 Property Rights and Limitations in the European Convention on Human Rights 140
3.3.3.4 Result 143
3.4 "CAN NOT BE JUDGED IN THE IMPLEMENTATION OF ADMINISTRATIVE TRANSACTIONS" FOR THE APPLICATION TO THE TAXES 144
3.4.1 CATEGORIES OF ADMINISTRATIVE ACTIONS 146
3.4.1.1 Action for Nullity 146
3.4.1.2 Full Remedy Action 147
3.4.2 QUALITY OF THE CASE OF TAXES 148
3.4.3 ADMINISTRATION COMPLIANCE AUTHORITY, INSTITUTIONAL CONTROL AND RE-SURVEY PRINCIPLES 150
3.4.4 EXPEDINCY AUTHORITY
3.4.5 Monitoring of discretionary 152
3.4.6 Orinciple of ex officio Examination 152
3.4.7 Boundaries of the judiciary 153
3.4.7.1 The Reason for the State Council 156
3.4.7.2 The judge can not exercise discretionary 156
3.4.8 Evaluation 167
3.4.9 CONCLUSION 170
3.4.10 REFERENCES 171
4.1 " ACCOUNTING FRAUD" IS IT POSSIBLE?
4.1.1 INTRODUCTION 173
4.1.2 Definition of Crimes, Subjects and Elements 173
4.1.2.1 Material Element of the Crime 175
4.1.2.2 Moral Element of the Crime 175
4.1.2.3 Illegality 175
4.1.3 TAX OFFENSES AND CRIMINALS 176
4.1.3.1 Birth of tax penalty law 177
4.1.3.2 Tax penalty and tax offense: 178
4.1.3.2.1 Tax offense: 178
4.1.3.2.2 Tax Offence Payer 178
4.1.4 FORENSIC TAX CRIMINALS 180
4.1.4.1 ACCEPTANCE OF ACCOUNTING AND ACCOUNTING OFFICERS 181
4.1.4.1.1 ACCOUNT AND ACCOUNTING CONCEPT 181
4.1.4.1.2 Definition of the account and the accounting and the acts to be deceived 182
4.1.4.1.3 THE INVESTIGATION OF THE ACCOUNTING DEPUTY SUCCESS FROM THE PRINCIPLES OF "SPECIFICITY" 187
4.1.4.1.3.1 The Principle of Determination in Criminal Law 187
4.1.4.1.3.2 Evaluating the criminal's accountability principle in order to make the account and accounting complex 190
4.1.5 CONCLUSION 192
4.1.6 REFERENCES 193
4.2 THE CAPITAL OF TAX ADMINISTRATION ON THE REST OF THE TAX OFFENSES AND THE CONSTITUTIONAL COURT 195
4.2.1 Introduction 195
4.2.2 TAX LAW AND CLEARANCE 195
4.2.2.1 The birth of tax penalty law 196
4.2.2.2 Tax penalty and tax offense: 197
4.2.2.3 Tax offense: 198
4.2.2.4 Tax Payer in the Situation: 198
4.2.2.5 Interruption of tax penalties: 198
4.2.3 EVALUATION OF THE CONSTITUTIONAL COURT OF THE CONSTITUTION 202
4.2.4 QUICK VIEWS ON THE FOLLOWING IMPLEMENTATION OF THE TAX ADMINISTRATIVE AGAIN
4.2.4.1 Opinion Defending the Essence of "The Law That Will Be Applied" in the Implementation of the Tax Criminal Penalty 204
4.2.4.1.1 Provisions in the Constitution and the Criminal Code on the Application of Criminal Laws in Time
4.2.4.1.2 Applicability of Time-Based Implementation of Criminal Code to Tax Criminal Punishment 208
4.2.4.2 Opinion defending the application of the Acts of the Act which the Act is committed in the past 211
4.2.5 EVALUATION 218
4.2.6 Result 220
4.3 QUALIFIED TAX ADMINISTRATIVE CRISIS (CONFLICT) DECISION SHOULD BE REQUIRED FOR THE CONSIDERATION OF FORECASTING AND CRIMINAL CUTTING 222
4.3.1 Introduction 222
4.3.2 Explanations and Legislation on Subject 222
4.3.2.1 Theoretical Explanations 222
4.3.2.2 Legislation on the subject 225
4.3.3 Administrative Procedure and Punishment 226
4.3.4 Eligibility for Qualified Tax Liability Crimes and Tax P.L. 227
4.3.4.1 Conditions Required to Cut Out a Qualified Tax Criminal Penalty 227
4.3.4.2 Due to the Taxpayer Act, Tax Needs to Reach 228
4.3.5 Reconciliation of Qualified Tax Credits 228
4.3.6 Result 231
4.3.7 References 232
4.4 THE RELATIONSHIP BETWEEN THE CONCEPT OF FORGE A DOCUMENT CRIME AND UNFUNCTIONAL CRIME OF T.P.L. 359 233
4.4.1 INTRODUCTION 233
4.4.2 Definition of Crimes, Subjects and Elements 234
4.4.3 "Fraudulent Document Arrangement" in Article 359 of the Tax Procedure Law 236
4.4.3.1 The concept of the document which is heldarranged in accordance with the Tax Laws and which has the obligation to keep and to submit it.
4.4.3.1.1 It must be a document issued in accordance with the tax laws of the document. 238
4.4.3.1.2 The document must be a document that is issued in the sense of the tax laws. 239
4.4.4 Non-Performable Offenses 240
4.4.5 Cases Where Fraudulent Document Editing Offenses Become Irreversible Offenses 241
4.4.6 CONCLUSION 244
5.1 STATUS OF INVESTMENT DISCOUNTS EXEMPLARY DATE BETWEEN 01.01.2006 - 08.04.2006 AND VESTED RIGHT 245
5.1.1 INTRODUCTION 245
5.1.2 SYSTEM INCLUDED WITH LAW NUMBER 5479
5.1.3 CONCEPTUAL CONCEPT OF VESTED RIGHTS 248
5.1.4 BACKWARD AND FORWARD TRANSACTION OF TAX LAW 250
5.1.5 Retrospectivity 253
5.1.6 RESOLUTIONS OF THE CONSTITUTIONAL COURT ON THE TIME OF IMPLEMENTATION OF TAX LAWS 255
5.1.7 EVALUATION 260
5.1.8 CONCLUSION 262
5.2 PROBLEM OF PREFERENCES FROM INVESTMENT DISCOUNT 264
5.2.1 INTRODUCTION 264
5.2.2 REGULATIONS OF THE MINISTRY OF FINANCE ON THE INCOME TAX LAW 264
5.2.3 HOW TO DETERMINE TAXPAYER’S CHOICE? 265
5.2.4 CAN I CHANGE THE CHOICE AFTER? 267
5.2.5 CONCLUSION 269
5.3 IMPLEMENTATION OF INVESTMENT DISCOUNT IN THE YEAR 2009 AND THE MEANING OF THE CONSTITUTIONAL COURT’ DECISION 270
5.3.1 Introduction 270
5.3.2 THE CONSTITUTIONAL RIGHTS OF THE CONSTITUTIONAL COURT 271
5.3.3 INVALIDITY IN TAX LAW 272
5.3.3.1 RETROSPECTIVITY 274
5.3.4 IMPORTANCE OF THE NULLITY OF THE CONSTITUTIONAL276
5.3.4.1 QUALITY OF NULLITY 276
5.3.4.2 UNDERSTANDING OF THE DECISION OF THE NULLITY 279
5.3.5 CONSIDERATION WAY APPROACH TO RETROSPECTIVITY... ..281
5.3.6 EVALUATION 284
5.3.7 CONCLUSION 287
5.3.8 REFERENCES 288
5.4 INVESTMENT DISCOUNT WITHOLDING 290
5.4.1 INTRODUCTION 290
5.4.1.1 REGULATIONS REGARDING INCOME TAX LAW 290
5.4.2 TIME LIMITATION CONCEPT 291
5.4.2.1 Elements 292
5.4.3 TAX PROCEDURE REGULATIONS 293
5.4.4 TOPIC RELATED CONSULTATION AND ACCOUNTING ADVISORY COMMITTEE CONSIDERATIONS 293
5.4.5 CONVERSION 296
5.4.6 CONCLUSION 297
5.4.7 REFERENCES 297
6.1 DIRECTIVE 2003/48 RELATED TO THE TAXATION OF INTEREST INCOME TAXES OBTAINED FROM THE EU AND REAL PEOPLE 299
6.1.1 Introduction 299
6.1.2 Scope of Directive 2003/48 300
6.1.2.1 Objectives and Definitions 302
6.1.2.2 Interest Payments 303
6.1.2.3 Information Exchange 304
6.1.2.4 Transition Period 304
6.1.2.5 Withholding 305
6.1.2.6 Revenue Sharing 305
6.1.2.7 Exceptions 305
6.1.2.8 Prevention of Double Taxation 306
6.1.3 Result 307
6.2 DIRECTIVES RELATED TO THE EVALUATION OF MARKET INCOME TAXES REMOVED BY THE EU BY DRAFTS IN TAXATION 308
6.2.1 Introduction 308
6.2.2 Directive 2003/49 on Taxation of Interest and Loan Payments Between Companies in Different Member States 308
6.2.3 Directive to Prevent Double Taxation of Dividends Distributed to Parent Company from Young Firms in Different Member States (90/435) 310
6.2.4 Result 311
6.3 TRANSFER PRICING 312
6.3.1 INTRODUCTION 312
6.3.2 Transfer pricing CONCEPT AND HISTORY 313
6.3.3 Transfer pricing methods used by businesses 314
6.3.3.1 Patch-Based Transfer pricing 314
6.3.3.2 Money Based Transfer pricing 315
6.3.3.3 Transfer Pricing Based on Variable Cost 315
6.3.3.4 Transfer Pricing Based on Total Cost 315
6.3.3.5 Interviews Determined Transfer pricing 316
6.3.4 REGARDING TRANSFER PRICING REGULATIONS OF THE UNITED STATES (USA) AND ECONOMIC COOPERATION AND DEVELOPMENT (OECD) 317
6.3.4.1 OECD REGULATIONS FOR TRANSFER PRICING 320
6.3.5 IMPLEMENTATION OF TRANSFER PRICING IN OUR OFFICE 323
6.3.5.1 APPLICABLE APPLICATION OF APPLIED GAINS IN TAX LAW NO. 5422 323
6.3.5.2 Disguised Profit Distribution Through Transfer Pricing in Law No. 5520 on Institutions Tax 325
6.3.5.2.1 Associated Person 326
6.3.5.2.2 The Employment Legality of Compliance 327
6.3.5.2.3 Methods to be applied in transfer pricing 329
6.3.5.2.3.1Collaborative Price Method 330
6.3.5.2.3.2 Cost Plus Method 331
6.3.5.2.3.3 Retail Price Method 332
6.3.5.2.3.4Parking Method: 334
6.3.5.2.3.4.1 The Net Margin Method based on Processing 334
6.3.5.2.3.5 Pure Pricing Agreement 335
6.3.5.3 Counterparty Adjustment 336
6.3.5.4 Authority given to the Council of Ministers 337
6.3.6 Evaluation and conclusion 337
6.3.7 REFERENCES 339
6.4 DISCOUNT IN TRANSPORTATION PRICING PROCEDURES DISCONTINUED VAT DECISION MADUAL? 341
6.4.1 INTRODUCTION 341
6.4.2 TRANSFER PRICING AND DISCOUNT VAT 341
6.4.2.1 The Place and Effect of the Transfer Pricing Regulation on Tax Procedures 341
6.4.2.2 Discount and Expense Terms 343
6.4.2.3 No action should be taken against the normal operation of VAT 344
6.4.3 RESULTS 345
6.5 TAXATION AND IMMEDIATE INTEREST INCREASES BY THE OECD MODEL AGREEMENT 346
6.5.1 INTRODUCTION 346
6.5.2 Overview 346
6.5.3 Principles on countries' taxation rights 347
6.5.3.1 Taxation on settlement basis 347
6.5.3.2 Taxation on the basis of the resource basis 347
6.5.3.3 Taxation on the basis of citizenship 348
6.5.4 Problems with international double taxation 348
6.5.4.1 Definition of double taxation 349
6.5.4.2 Prevention of double taxation 350
6.5.4.3 Prevention of unilateral arrangements and double taxation in the Internal Law 350
6.5.4.3.1 Offset Method 350
6.5.4.3.2 Exception Method 350
6.5.4.3.3 Expense Method 351
6.5.4.4 Prevention of Double Taxation by Participating in International Economic Integration 351
6.5.4.4.1 Prevention of Double Taxation with International Agreements 352
6.5.4.4.1.1 Key Features and History of the Tax Treaties 352
6.5.4.4.2 The Importance of the OECD Tax Treaty 353
6.5.4.4.2.1 The OECD Model Taxation Convention Content and Basic Taxation Principles 354
6.5.4.4.2.2 Income and Wealth Elements that may be Taxed in the Country of Origin and Source Country by the OECD Model Tax Agreement 355
6.5.4.4.2.2.1 Revenues that may be taxable within the framework of certain restrictions in the Resource Country 356
6.5.4.4.2.2.2 Revenues not to be Taxed in the Resource Country 356
6.5.5 Taxation of Dividends 357
6.5.5.1 Article Text 357
6.5.5.2 Drawbacks of Turkey in Article 10 of the OECD Model Agreement 358
6.5.5.3 Definition of Dividend Term 359
6.5.5.4 Taxation of the State in which the Dividend Holder Persons Reside Article 360
6.5.5.5 Taxation of the State of the State in Which the Dividend-Free Corporation Resides Article 360
6.5.5.6 Dividend Cases 363
6.5.5.7 Where the dividends paid by a State Settlement Organization will not be taxed by the other State 364
6.5.6 Taxation of interest income 365
6.5.6.1 Article text 365
6.5.6.2 Capturing Turkey's Article 11 of the OECD Model Agreement 366
6.5.6.3 Definition of Interest Article 366
6.5.6.4 Taxation of Interest Income 367
6.5.7 EVALUATION 368
6.5.8 Result 370
6.5.9 REFERENCES 370
6.6 TAXATION OF ROYALTIAL PAYMENTS IN INTERNATIONAL TAXATION AGREEMENTS 372
6.6.1 Definition of royalties 372
6.6.2 The Royals in the OECD Model Agreement: Definition and Elements 376
6.6.3 Taxation of the PAYMENTS set forth in Article 12 of the OECD Model Agreement 378
6.6.3.1 Internal taxation 378
6.6.3.1.1 In terms of Income Tax 378
6.6.3.1.1.1 Property Lease for Real Estate 378
6.6.3.1.1.2Tax Gain 380
6.6.3.1.1.3 Net Profit 380
6.6.3.1.1.4 Free Profit Profit 380
6.6.3.1.1.5Gain Earnings and Bills 381
6.6.3.2 From the point of view of Corporate Tax 381
6.6.4 Taxation in the OECD Model Agreement 382
6.6.4.1 Earnings to be Taxed as Royalties 382
6.6.4.2 Earnings Not Covered by the Royalties 383
6.6.4.2.1 Earnings to be Taxed as Commercial Gains 383
6.6.4.2.2 Earnings to be Taxed as Capital Increase in Earnings 384
6.6.4.2.3 Regulation on Transfer Pricing 385
6.6.5 Know-how 388
6.6.5.1 Declarations Made in the Commentary of the OECD Model Agreement on Know-How 389
6.6.6 CONCLUSION 391
6.7 WHAT IS BENEFICIAL OWNER-OWNERSHIP IN THE TAXATION AGREEMENTS? 393
6.7.1 INTRODUCTION 393
6.7.2 DEFINITION OF CONCEPT 393
6.7.3 THE BENEFICIAL OWNER IN THE TAXATION AGREEMENTS 394
6.7.4 PROBLEMS RELATED TO CLAIM 395
6.7.5 CONCLUSIONS 3977.
THEORETICAL SETTLEMENTS OF INCOME TAX
7.1 REASONS FOR INVESTORS FROM CHANGES IN INCOME TAX SYSTEMS AND SYSTEMS WHICH APPLIED FOR IMPLEMENTING INCOME TAXES WORLDWIDE 398
7.1.1 Introduction 398
7.1.2 Causes of Reform in Revenue Taxes 399
7.1.2.1 Financial Pressures 400
7.1.2.2 Tax Scam 401
7.1.2.3 Distribution of Income 402
7.1.2.4 Complication of the Tax System 403
7.1.2.5 External Pressures 403
7.1.3 Implementing Systems in the World on Income Tax 404
7.1.3.1 Comprehensive Income Tax System 405
7.1.3.2 Flat Taxation (Flat Tax) 407
7.1.3.3 Dual Income Tax 409
7.1.3.3.1 Reviews of the Dual Income Tax System 412
7.1.3.3.2 The Equilibrium Direction of the Dual Income Tax System 413
7.1.3.3.3 Taxation of Capital Inflows in the Inflation Economy
7.1.3.3.4 Taxation of Human Capital 415
7.1.3.3.5 Taxation of Vertical Equality, Capital Income and Income from Capital 417
7.1.3.3.6 Efficiency Direction of the Dual Income Tax System 419
7.1.3.3.7 Income Argument 420
7.1.3.3.8 Impartiality Thesis 420
7.1.3.3.9 Saving Thesis 421
7.1.3.3.10 The Relationship Between Revenue and Institutions Tax in the Dual Income Tax System: 421
7.1.3.3.11 Taxation of Small Entrepreneurs in the Dual Income Tax System: The Weak Point of the Dual Income Tax System 422
7.1.3.3.12 Taxation of Active Ownership Formations in the Dual Income Tax System 423
7.1.3.4 Semi-Dual Income Tax System 424
7.1.4 Result 429
8.1 CAPITAL INCREASE IN SOURCE AND FUND 432
8.1.1 INTRODUCTION 432
8.1.2 ARRANGEMENTS IN THE TCC 432
8.1.2.1 First Clause of the 462nd Article 432
8.1.2.2 Second Clause of 462. 433
8.1.3 WHAT IS THE AIM OF BAN ON THE FUND AND LAW? 433
8.1.4 CONCLUSION 434
8.2 THE LAST SITUATION IN ACCOUNTS PAYABLE TO PARTNERS 436
8.2.1 INTRODUCTION 436
8.2.2 Placement of Receivables as Same Capital 436
8.2.3 Why is it important? 437
8.2.4 What is the Current Situation? 437
8.2.5 EVALUATION AND CONCLUSION 438
8.3 CONCEPT OF TRADE GAINS BY NEW TURKISH TRADE AND TAX LAW 440
8.3.1 INTRODUCTION 440
8.3.2 TRADE LAW REGULATION 440
8.3.3 COMMERCIAL BUSINESS ADMINISTRATION AND COMPONENTS 440
8.3.3.1 Generally 440
8.3.3.2 Commercial Business 441
8.3.3.2.1 Business Operational Elements 442
8.3.3.2.1.1 Targeting Targeting 442
8.3.3.2.1.2Uniformity 442
8.3.3.2.1.3Consumption 443
8.3.3.2.1.4 Exceeding Limits of Employee Activity 443
8.3.4 Commercial Income in Tax Law 443
8.3.4.1.1 Trade Earnings Value 443
8.3.4.1.2 Scope of Commercial Activity 445
8.3.4.1.2.1 Consistency in Business Activity 445
8.3.5 CONDITIONS OF REAL ESTATE AGAINST TURKISH TRADE LAW 446
8.3.5.1 Commercial Operator Operator-Operated Commercial Operator 447
8.3.5.2 Business Operator Prepared to Operate 447
8.3.5.3 The Person Who Makes an Imagination That a Non-Commercial Business Operates on Its Own 448
8.3.5.4 Business Operator Partner of the Business Partner Image Maker Maker 449
8.3.6 Commercial Business Presumption 449
8.3.7 REFERENCE 450