Interpretation differences between tax judiciary and tax administration

On the basis of the study, it is necessary to interpret the provisions of the law in tax law in accordance with Article 3 of the TPL No.213, but the reasons for the judiciary's interpretation of the same article of the same law as a result of the administration's interpretation of the transaction, Solutions aimed at minimizing these differences have been tried to be presented. In order for the tax laws to be applied correctly, the provisions of the law should be clearly interpreted. The administration aims to apply the intangible tax law laws to concrete events in the most accurate way. However, the relevant abstract tax laws may not exactly overlap with every tax event. Since the administration does not have the option of not establishing a transaction within the scope of duty, it interprets and applies the relevant law article according to the 3rd article of the TPL without harming the principle of legality of tax. However, since this interpretation cannot always be in favor of the party to which the transaction is established, this situation may be referred to the judiciary as a requirement of being a state of law. By making his/her own interpretation in the judiciary, he/she can disrupt the transaction of the administration and decide. The reasons for the differences in interpretation between the tax administration and the tax judiciary, which are the subject of the study, are intended to be explained in 2 sections within the scope of the studies and sample judicial decisions. In the first part, the concept of interpretation in general, its interpretation, types, types, etc. in tax law. It has been explained. In the second part, the reasons for the differences in interpretation between the tax administration and the tax judiciary are explained with exemplary judicial decisions, and the solutions for these interpretation differences are explained. In the conclusion part, solutions are explained due to the differences in interpretation.