Turkey introduces ‘electronic place of business’ concept

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Turkey introduces ‘electronic place of business’ concept

Turkey, as one of the founding members of the OECD and partner of the G20, is in full swing with the adoption of BEPS Project recommendations.

Six of the 15 key tools have already been translated  into law and other new legislative amendments in the context of BEPS are waiting to be enacted.

Meanwhile, Turkey is also modernising and simplifying its tax system and legislation by adopting international standards whereby the use of technology tools is strongly encouraged.

The use of technology and the internet is something to be welcomed, but the downside is that it has also opened opportunities for multinationals to avoid incorporation in the source state. 

However, Turkey is almost ready to reveal the ‘electronic permanent establishment’ concept to discourage the avoidance of a taxable PE presence of multinationals.

Profits are generally taxed where the economic activities occur and where the value is created. However, the internet has reshaped the global economy by allowing multinationals to shift towards a cross-border digital economy.

In particular, the increased delivery of services and goods conducted via electronic means has opened new opportunities for multinationals to avoid the pyhsical settlement in the source country to pay less tax, or avoid  it completely. 

This has resulted in a huge loss of revenue for governments that could be otherwise generated from multinationals active in the e-business environment.

Turkey’s legislation already contains anti-avoidance measures in line with the goals of the BEPS project against harmful tax planning and competition. 

Though, the supportive attitude of Turkey is also reflected in the e-commerce area along with thenew tax legislation, which will be unveiled soon.

As a result of new tax challenges of the digital economy, the Turkish government has recently introduced the draft of article 129 and 130 in the Tax Procedural Law No. 213 by introducing the concept of an ‘electronic taxpayer’ and 'electronic place of business’.  

This new draft legislation is a reflection of BEPS Action 7, which aims to prevent artificial avoidance of permanent establishment status by increasing the occasions on which a PE could be created. 

Hence, according to the draft of article 130 of the Turkish Procedural Law, the use of internet, intranet or other similar telecommunication tools for commercial, industrial or professional activities might create an electronic workplace allowing profits derived through these e-commerce activities to be taxed accordingly in Turkey. 

By revealing this new digital taxation formula, the compliance position of multinationals (especially of social media firms) in Turkey, who derive income from e-commerce activities targeted to Turkish individuals, will change completely. 

Ayse Devranoglu (ayse.devranoglu@wts-turkey.com / +90 212 347 4125) is a tax consultant at WTS Turkey, member of WTS Global

more across site & shared bottom lb ros

More from across our site

The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series
Gift this article