Participation shares, founder's shares, usufruct shares, preference rights and real estate sales income exemption within the scope of own corporate tax

It is targeted to strengthen the financial structures of the institutions by exempting the incomes that may be subject to tax exemption from corporate tax, and to prevent repeated taxation thanks to the implementation of corporate tax. In this study, the emergence of the concept of tax exemption, the development of the regulations, the activities that may be subject to the exemption are specified, and more assiduously, the scope of exemption of participation shares, founder shares, usufruct shares, preference rights and real estate sales income from corporate tax, views in doctrine and practice, higher judicial decisions were inspected. As a result of the examination, the inconsistencies between the doctrine and the practice were determined and the views on the purpose to be achieved with the reasoning of the legal regulation subject to the exception were introduced.The study consists of three parts. In the first part, the effect of the exemption application in corporate tax and the legal amendments made until today, the relationship between the concept of tax expenditure and the concept of exception are explained, and then the exception provisions in corporate tax are given. In the second part, the provisions of participation shares, founders' shares, usufruct shares, preference rights and exemption from corporate tax of income from real estate sales, which are the subject of the thesis, are examined in detail; explanations were made in terms of limited taxpayers and full taxpayers; The limits of the exception application in terms of duration, rate and field of activity are expressed. In the third chapter, the solutions of the disputes between the taxpayer and the tax administration in the application of the exemption provisions in the light of rulings and judicial decisions are mentioned.