Micro tax planning: The place and importance of tax arbitrage practice in Turkish Tax Law

Tax planning is an irreplaceable practice for economic actors to survive. Tax planning comprises of literary, practice, global etc. several different paradigms (a string of values). As literary, while the answer to the question "What is tax planning?" remains unchanged, paradigm shifts may often ocur in terms of local and global practices. This paradigm shifts, from a local perspective, while may be practices such as changes in the tax legislation that we frequently encounter; from a global perspective, we can exemplify eventuating with differences of legislative change between countires that reflects to practices. Tax planning consists of string of values which makes it both a sophisticated practice and also can pose many difficulties for its practitioners. The tax planning is used mainly by two actors as micro and macro tax planning; the part planned by the goverment is macro tax planning; the part planned by the taxpayers is micro tax planning. In the first and second chapters of our thesis, tax planning and tax arbitrage practice have been put forward with a theoretical analysis in terms of taxpayers and goverment and the historical framework of these practices which have a sophisticated feature has been tried to be drawn. In the last chapter of the thesis, tax arbitrage opportunities of the taxpayers in Turkish Tax Law presented by staying in adjective tax law limits.