Controlled foreign corporation(CFC) regulation as an anti-tax evasion mechanism and its evaluation of Turkey in the light of foreign experiences

In this thesis, we aim to study on the efficiency of controlled foreign corporation regulation at Turkey, which was introduced in 2006, by covering all aspects of the issue by refering the other country experiences of the same mechanism and covering all the relevant legal arrangements.In the first chapter of the paper, we discuss the rationale for setting up the controlled foreign mechanism, the description, the elements and the common features of this regulation. We also take into account the other country experiences of the same regulation, the compatibility of this regulation with Acquis Communitaire, the relation of the mechanism with double taxation treaties.In the second chapter, we desire to cover the relevant legal arrangements in Turkish tax law as regards to controlled foreign corporations, the relation of this mechanism with other tax issues such as transfer pricing, thin capitalization, withholding from all payments to tax haven countries and the foreign tax credit. We also struggle to display the problems encountered up to now and the potential problems which we would expect to encounter as regards to this mechanism.In the last chapter, we note the efficiency performance of the controlled foreign corporation mechanism in the light of 5 years experience and introduce our solutions to resolve the the problems encountered up to now and the potential problems which we would expect to encounter.