1. Elimination of Reconciliation Rights for Principal Tax Liabilities

Under the amendments introduced by Law No. 7524, principal tax liabilities can no longer be subject to reconciliation. Reconciliation applications will now only apply to tax loss penalties and irregularity or special irregularity fines exceeding 23,000 TRY. Even if reconciliation is achieved, taxpayers will retain the right to litigate regarding the principal tax amount. Furthermore, the 25% discount applied when reconciled amounts are paid on time has been abolished.

However, for reconciliation applications filed before the publication date of the law, where no reconciliation meeting has been scheduled or such meetings have been postponed, the previous regulations will remain applicable, allowing principal tax liabilities to be included in the reconciliation process.

2. Reporting Obligations for Digital Service Providers

Amendments to the repealed Article 257 of the Tax Procedure Law expand the reporting obligations for digital service providers and intermediary institutions. The new provisions also encompass access providers, content providers, hosting providers, and social network providers. The Ministry of Treasury and Finance may impose additional obligations on these entities to collect information related to electronic commerce transactions.

3. Valuation of Precious Metals Based on Stock Exchange Prices

A notable innovation under the law is the option to use stock exchange prices for the valuation of precious metals. In cases where no stock exchange price exists, or the price is deemed collusive, the cost price will apply. Companies with receivables or payables in precious metals will also adopt this new valuation method.

4. Increased Penalties for Failure to Register Tax Liabilities

The penalty for engaging in commercial, agricultural, or professional activities without registering tax liabilities has been increased by 50%.

5. Changes to Irregularity and Special Irregularity Fines

Significant increases have been made to irregularity and special irregularity fines. Penalties for failing to issue tax-related documents will vary depending on the number of offenses committed within a calendar year. In cases of multiple omissions of the same type of document, separate penalties will be imposed for each omission. Furthermore, penalties will be applied at different rates if these documents are reported to the tax authorities.

6. New Measures Against Issuers of False Documents

The provisions for the discretionary cancellation of tax registration for individuals issuing false documents without engaging in actual commercial activities have been expanded. A guarantee requirement has been introduced for re-establishing tax registration, with the upper limit set at 10 million TRY. If the individuals involved assume similar roles in other companies, additional guarantees must be provided, or such roles must be terminated.