In 2015, the sub-article ı) was
added to article 10. This sub-article allows the taxpayers to deduct certain
portion of the cash/liquidity infusion to the company’s paid-in equity
structure from the CIT base. A defined interest rate is applied to the cash
infusion and 50% of this amount (for the cash brought from abroad 75% rate
applicable) is deductable from the CIT base. This right was used by the
taxpayers for an indefinite period i.e. as long as there is no withdrawal from
the company’s equity, they were deducting these amounts from their tax base
year by year. However, Law 7417 brought a 5 year time limit for the application
of this deduction. Companies can apply these deductions for the year of the
cash infusion and the following 4 years. If a company doesn’t have a tax base
for the related years, it can still apply the deduction in the future even if
the 5 year time limit expires. Companies who have increased their paid-in
capital with cash infusions in the past can still apply these deductions for 5
years starting from 2022, regardless of the number of terms in the past that
they benefited from this deduction. The amendment came into force on
05.07.2022.