What is the status of the payments made for the purchase of services such as finding customers and marketing from limited taxpayer corporations in relation to goods and services exported abroad?

If the activity of the company serving abroad in relation to the goods and services exported abroad consists of finding customers and receiving commissions on the price of goods sold, this business will be evaluated as a commercial activity and no tax deduction will be made in accordance with Article 30 of the Corporate Tax Law No. 5520.

However, in the event of overseas market research, advertising of products, marketing and management services and exceeding brokerage service,  these services will be considered as self-employment services and 20% of corporate tax deduction will be required, in accordance with Article 30/1-b of the Corporate Tax Law, pursuant to the Decision of the Council of Ministers No. 2009/14593.

On the other hand, the provisions of the double taxation agreements concerning self-employment activities will be taken into consideration first.

Source: GİB
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