Turkey

Deloitte

Deloitte Values House

Maslak Mahallesi, Eski Büyükdere Cad. No:1

Maslak No 1 Plaza

34398, Maslak – Sariyer, Istanbul

Turkey

Tel: +90 212 366 60 72

Mobile: +90 533 275 70 03

Email: hyilmaz@deloitte.com

Website: www.deloitte.com

Guler Hülya Yilmaz is a sworn certified financial consultant who leads the cross-border tax service line and has been responsible for the transfer pricing (TP) service line in the Turkish tax practice since June 2006. She started her career as an independent auditor in the audit department of the former Arthur Andersen in 1989 after her graduation from university. Hülya has specialised in international tax consultancy services since she began her career at Deloitte in 1993 after her post-graduate studies. She has significant experience in tax consultancy and tax planning that involves transfer pricing, legal and international tax aspects. She has also been actively involved in tax structuring for major M&A projects in Turkey.

Hülya became a tax partner in Deloitte Turkey's tax practice on June 1 2006 (as the first female tax partner within the Big 4 in Turkey). She is also the country leader for the life science and healthcare industry and is the Tax Learning Leader in Deloitte Turkey. She also has significant experience in serving multinational firms in the energy sector. She advises multinational clients in tax matters related to permanent establishment issues, application of tax treaties, restructuring, tax and TP related tax audit cases.

Her transfer pricing work covers TP documentation and planning projects across various sectors; cost allocation analysis and cost-sharing agreements; tax analysis of IP transfer or migration plans; TP audit defence; unilateral APA applications; TP analysis of contract R&D applications; and comparative analysis of the treatment of related party transactions in the New Turkish Commercial Code versus the Turkish Capital Market Law, considering the underlying TP implications.

Hülya is experienced in tax modeling and consultancy for energy project companies operating under the financing models of 'build-operate-transfer' (BOT) and 'transfer of operation rights' (TOR). She provides transfer pricing consultancy regarding unbundling transactions in the energy industry (generation, transmission, distribution, shared services and so on) under alternative tax structures. Hülya also provides TP documentation studies for the trading of specific materials in the mining sector (used in power generation) between related parties. She also has experience in income and profit attribution in relation to 'turnkey projects'.

Hülya speaks English and Turkish and has working knowledge of French. She holds a bachelor of arts degree in business administration from Marmara University and a master's degree in business administration from the Bogazici University.

She is a sworn financial consultant; a member of the Istanbul Chamber of Sworn Financial Consultants; a member of the Turkish branch of IFA; a member of the Association of Foreign Investors in Turkey (YASED) working group on life sciences and healthcare; and a member of the healthcare committee in the American Business Forum in Turkey, part of the American Chamber of Commerce (AmCham) Turkey.