Süleyman Hayri B ALCI Head of Department Department of EU and Foreign Affairs

1. EXCHANGE OF INFORMATION IN TURKEY SüleymanHayri BALCI Head of Department Department of EU and Foreign Affairs Presidency of Revenue Administration İstanbul, 23-24 May 2013

2. EOI IN TURKEY • EOI In General(Legal Base) • OrganizationalStructure of EOI Unit • EOI Process

3. EOI In General (Legal Base)

4. Turkey; • attributes high importance to exchange of information • has no restrictive provisions in its domestic law (bank information, partnership information, etc. can be exchanged) • As a member Turkey supports the work of Global Forum on Transparency and Exchange of Information for Tax Purposes.

5. Legal Basis of Exchange of Information in Turkey Double Taxation Agreements (DTAs) Agreement on Exchange of Information on Tax Matters Convention on Mutual Administrative Assistance in Tax Matters

6. Double Taxation Agreements • Turkey exchanges information within the scope of Double Taxation Agreements. • Article 26 of OECD Model Tax Convention is the basis of exchange of information article in Turkey’s DTA’s.

7. Double Taxation Agreements • Turkey has signed 82 ( 4 of themrevised) DTAs; 78 of them are in force. • Recently signed DTAs of Turkey include new version of Article 26. • Turkey also has been revising Article 26 in its old-dated DTAs in accordance with the new version of this Article.

8. Agreement on Exchange of Information • on Tax Matters(TIEAs) • ●In accordance with the international developments in the field of transparency and exchange of information for tax purposes, Turkey continues to expand its network of TIEA’s

9. Convention on Mutual Administrative Assistance in Tax Matters • Signed on 3 November 2011 • Come into force following ratification by the Parliament (It is in the Parliament)

10. EXCHANGE OF INFORMATION ORGANIZATION IN TURKEY

11. International Exchange of Information Section • Organized only at the central level. • Works under the competent authority for EOI and all matters regarding DTAs. • Competent Authority: Minister of Finance or his authorized representative. • Handles all requests made under EOI mechanisms. • Works in close cooperation with DTA Sections at the central level and with Tax Office Directorates/Revenue Offices at the local level, as well as with Tax Inspection Board.

12. COMPETENT AUTHORITIES COMMISSIONER Mehmet KİLCİ DEPUTY COMMISSIONER Mehmet ATUĞ HEAD OF DEPARTMENT EU AND FOREIGN AFFAIRS Süleyman Hayri BALCI HEAD OF GROUPKaan KASIM International Exchange of Information Section

13. COMMISSIONER OF THE REVENUE ADMINISTRATION Deputy Commissioner Head of Department of EU and Foreign Affairs Head of Group Double Taxation Agreements –Section I Double Taxation Agreements -Section II International Exchange Of Information Section EU Section Section for Bilateral and Multilateral Agreements OECD Section

14. MANAGER OF EOI SECTION Number of Staff 9 Revenue Experts (6) Translators (3)

15. EXCHANGE OF INFORMATION PROCESS IN TURKEY

16. Incoming Requests FOREIGN JURISDICTION Response sent Sends a request EOI SECTION Request checked. Valid? Sends a report Clarification or additional information is sought. no TIB yes no Can EOI Unit respond directly? Response prepared directly by the EOI Section and forwarded INCOMING REQUESTS yes

17. EOIStatistics • Number of incoming requests are calculated as; where one taxpayer (individual or entity) about whom information is requested is counted as one request, since a separate investigation is needed for each taxpayer. So one letter may be counted as three requests if it seeks information about three taxpayers. • Based on the calculation method described above, from 2009 to the end of 2011 Turkey received 518 requests from Treaty Partners. • The first 5 countries that made requests most from Turkey were Ukraine, Russia, Bulgaria, Germany, United Kingdom • Turkey’s requests were mostly from theUnited Kingdom, United States, Italy,Netherlands, Germany.

18. Automatic Information / Spontaneous Information • Turkey receives and sends information on spontaneous basis. • Turkey has received AEOI from 9 countries thus far and the number of countries providing AEOI is increasing every year. • We have received approximately 8,000 recordsbetween 2009-2011 including information about immovable properties, payments of dividends, interest, royalties, pensions, salaries etc. • Turkey follows and supports OECD work on automatic exchange of information. • Turkey is planning to provide AEOI since reciprocity is an important element in all types of exchange of information. • We are in search of ways to make the AEOI received processed easier and faster in a more efficient way.

19. THANK YOU!..