Legal nature of special privileges in Turkish Tax Law

In Turkish tax law, with the article titled "Taxpayer's request for clarification" in the Tax Procedure Law No. 213, it is possible for taxpayers to request an opinion from the tax administration about the issues that they have doubts and hesitations during tax applications. As a result of the interpretation of the tax legislation regarding the matter for which the taxpayer requests an opinion, the tax administration notifies the taxpayer with a special tax ruling. The opinion of the tax administration, i.e. the special notices, only protected the taxpayer requesting the opinion from penalties and interest and did not protect other taxpayers in the same situation. In addition, due to the different authorities authorized to issue special notices, different special notices could be issued on similar issues. However, over time, amendments were made in the provision of law regarding the special tax ruling and regulations were made regarding the binding nature of the special tax rulings. In this study, an evaluation has been made regarding the changes in the legal nature of the special privileges as a result of the amendments made in the special privilege institution and the increase in the binding nature of the special privileges.