Divergent Interpretation about Software Payments under Turkish Tax Treaty Law
Journal
Brazil; India; International; OECD; Spain; Türkiye
Bulletin for International Taxation 2025 (Volume 79), No. 8
This article analyses Türkiye’s inconsistent classification of software payments under tax treaties, diverging from OECD and UN standards. It examines key rulings and recommends clearer administrative guidance and treaty-based judicial interpretation to reduce double taxation risks and align with international norms.