Article 50

Tax avoidance, as defined in Article 33(1) of the Law, involves entering into agreements, operations, or transactions where one of the primary goals is to reduce taxable income, create a loss, increase a loss, or use double taxation agreements for this purpose, including cases where the due tax amount becomes negligible.

"Tax benefit," in applying the provisions of Article 33(1) of the Law, specifically includes:

1. Reducing the tax due by reducing total income or increasing deductions or losses.

2. Obtaining a tax exemption.

3. Refunding tax amounts or financial penalties paid.

The agreements, operations, and transactions referred to in Article 33(1) of the Law, particularly include:

1. Agreements, operations, and transactions organized and executed through an arrangement or a series of interconnected arrangements aimed at tax avoidance. This provision does not apply to agreements, operations, and transactions undertaken in good faith for legitimate business purposes, where tax avoidance is not a primary goal.

2. Agreements, operations, and transactions involving the taxpayer splitting and partially or wholly transferring income to another person or persons linked to them for the purpose of avoiding tax fully or partially.

Tax benefits are withdrawn by the Authority in cases stipulated in Article 33 of the Law by a tax assessment decision according to Article 14 of the Law. To determine the tax due in such cases, the value of the benefit obtained by the taxpayer from the withdrawn tax benefit is added to the taxable income.