Investment Structure

For international investors, capital structuring, holding or SPV usage, tax planning and asset protection strategies are of critical importance. Emir Law & Consulting provides advisory to help you optimise your investment structure and protect your assets within the framework of Turkish tax legislation, double taxation treaties and investment incentives.

Holding and SPV (Special Purpose Vehicle)

Holding structures established in Türkiye or abroad enable you to consolidate multiple investments under a single umbrella and achieve tax efficiency in dividend distribution, share transfers and group financing. The use of a special purpose vehicle (SPV) is common for isolating investment in a specific asset or project, limiting risk and facilitating financing where necessary. Holding and SPV structures established under the correct legal and tax regime create significant differences in terms of corporate tax, withholding tax and indirect taxes.

Double Taxation Treaties (DTAs)

The double taxation treaties signed by Türkiye with numerous countries regulate residency, permanent establishment concepts, withholding rates on interest, dividend and royalty payments and which country has the right to tax. Positioning your investment structure in alignment with Turkish and treaty-country legislation prevents double taxation and generally reduces the withholding burden. We provide advisory on residency certificates, beneficial owner analysis and correct application of treaty provisions under DTAs.

Investment Incentives and Incentive Certificates

Investors who obtain an investment incentive certificate in Türkiye may benefit from advantages such as VAT exemption, customs duty exemption, tax reduction, employer's share social security premium support and interest rate support depending on the zone and sector. Additional support is available for regional incentives (priority investment zones, organised industrial zones) and strategic investments. We provide legal and administrative guidance to determine the most suitable incentive package based on your investment amount, sector and location and to manage the application process correctly.

Transfer Pricing and Related-Party Transactions

Compliance with transfer pricing rules is mandatory for goods, services and financing transactions between group companies or related parties. Turkish legislation adopts the arm's length principle in alignment with OECD guidelines; transfer pricing reports and documentation may need to be prepared for transactions exceeding certain thresholds. Incomplete or incorrect documentation leads to penalties and tax adjustments. We provide advisory on the identification of your related-party transactions, method selection and reporting processes.

Asset Protection and Estate Planning

It is possible to structure your investment in alignment with asset protection and long-term estate planning. Family businesses, share transfers, intergenerational transitions and the interaction of trusts/similar structures with Turkish law must be carefully addressed from tax and succession perspectives. Tag-along, drag-along, pre-emption rights and share transfer restrictions in partnership and shareholder agreements have both operational and tax consequences. We provide support in structure recommendations and preparation of contract texts in these areas.

Our Services

• Investment structure and holding / SPV formation advisory
• Analysis of the impact of corporate tax, VAT and withholding regimes on your investment
• Tax planning under double taxation treaties (DTAs)
• Assessment of investment incentive certificates and regional/sectoral incentives
• Tax and share transfer provisions in partnership and shareholder agreements
• Structure recommendations aligned with asset protection and estate planning
• Transfer pricing and related-party transaction compliance advisory

Why Emir Law?

Tax and structural decisions directly affect long-term costs and risks. Our team evaluates Turkish and international tax rules in conjunction, guiding you in establishing your investment structure in a manner that is both legally and tax-efficient.