In a tax audit, manage defence and negotiation in a single strategy.
From the first notice of the audit to the settlement table and, if necessary, to tax litigation; management of documents, defence and strategy throughout the process.
An audit is a process, not a single event
A tax audit begins with the submission of books and records, proceeds through information requests and cross-audits, reaches its critical threshold with the record of findings and concludes with the tax audit report. Each stage has its own strategy: which document is presented in which context, which reservations (ihtirazi kayıt) are entered into the record, and how the right to be heard before the report evaluation commission is exercised directly affect the outcome. In companies with foreign capital, transfer pricing, intra-group service charges and VAT refunds are the most frequent audit topics.
Settlement: the rules of negotiation
Settlement is a statutory mechanism through which the principal tax and penalties can be negotiated, either before or after assessment; its scope and thresholds are updated periodically through legislative changes. Before sitting down at the table, three things must be clear: the legal strength of the file (the likelihood of winning in court), the cash and provision plan, and the priority of the items to be conceded or preserved. The settlement record is final — once signed, the path to litigation is closed; this is why the negotiating-table strategy is built together with the litigation analysis.
The litigation crossroads
If settlement cannot be reached, litigation before the tax court follows — a field where the time limits are short and the burden of proof is carried by technical documents. The documentation and records built up during the audit form the evidentiary foundation of the case — which is why preparation “for what lies ahead” begins on the first day of the audit. In group structures, the outcome feeds back into the tax-compliance framework and the accounting-record discipline.
Deadlines and the statutory anchors
The framework is the Tax Procedure Law (VUK, No. 213): as a rule a limited audit must be completed within six months and a full audit within one year, and the invitation to explain (Article 370) allows a correction without entering an audit at all where its conditions are met. After an assessment based on the report, the fork in the road runs on strict deadlines: the period for bringing an action in the tax court is thirty days; an application for settlement is made within that period, and if no settlement is reached the remaining time starts to run again — topped up to fifteen days where fewer than fifteen remain. Keeping that calendar on a single page is often more vital than the strategy discussion itself.
Who is it for, and what do you get?
The companies that come to the table are most often those that have received an audit notice, exporters under a VAT refund audit, and multinational subsidiaries whose intra-group transactions are being questioned.
What you get: the audit defence file and a set of annotations to the minutes, a settlement decision tree, the groundwork for the statement of claim, and briefing notes for management. For those who want the commercial rationale for a structure documented in advance there is our tax modelling service, and for contested items our legal opinion practice.
The accountant and the legal team sit down at the settlement table with a single file, and the scenario calculations are kept in a form that can be updated during the meeting.
We are by your side for Tax Audit & Settlement
We manage the audit together with your accountant but with the discipline of legal defence: correspondence and deadline scheduling, record strategy, settlement modelling (scenario-based calculation) and, if necessary, litigation. For companies with German ties, we assess double-taxation-treaty arguments and the mutual agreement procedure (MAP) option with our Germany Desk. On the preventive side, the check-up routine of our Tax focus is engaged.
Other Applications of This Service
Tax Compliance — our other specialised solutions in this area.
Matter Connections
The focus areas, practice areas, desks and legislation connected with this sub-service.
Our Matters in This Service
The anonymised examples of our work that relate to this service.
Cross-border acquisition of a manufacturing facility in Türkiye
End-to-end representation of the buyer in a multi-jurisdictional acquisition, from due diligence to closing.
Review the matter →Investment · GreenfieldStructuring an incentivised manufacturing investment
Management of company formation, the incentive certificate and compliance processes in a greenfield investment.
Review the matter →Dispute · TaxConcluding a tax audit through settlement
In a transfer-pricing-focused audit; representation from the minutes stage through report assessment, and execution of the settlement strategy.
Review the matter →The Team Delivering This Service
With our multilingual team of lawyers, well-versed in Turkish and German law, we are by your side.
Related Publications
Fresh perspectives and guides from the Knowledge Centre.
Attending the meeting does not affect it; signing the settlement MINUTES is final and closes the litigation route. For items on which no settlement is reached, the litigation period runs anew from the minutes.
Defending the benchmarking analysis and the documentation is essential; group agreements and evidence of services actually rendered are decisive. If necessary, the double taxation treaty and the MAP process are brought into play.
Clarify the submission deadline and the scope, do not hand over the document set without running it through a legal filter, and put oral explanations on a written footing. The first contact sets the tone of the audit.
There is no single rate; it varies with the strength of the file, the type of item and the conditions of the period. A realistic range can only be built together with an analysis of the litigation prospects — we model this…
Tax Audit & Settlement — get the right legal support.
Let us identify the right solution together, drawing on our experience in Türkiye and the DACH region.