Örtülü sermaye uygulamasında ortaya çıkabilecek kur farklarının değerlendirilmesi.

There are some tax security measures in the Corporate Tax Law practice in Turkey. One of these tax security institutions, "Thin Capitalization", is regulated in Article 12 of the Corporate Tax Law No. 5520. The aforementioned regulation is based on the principle that the debts borrowed by the institutions from their partners or persons related to the partners, exceeding three times the equity capital of the institution at any time during the accounting period, is not considered as a borrowing, but as a capital that has been put into the institution in disguise. According to this practice, it is not possible to consider the part of the negative exchange rate differences that arise due to the increases in foreign exchange rates, which corresponds to the thin capitalization, as an expense in the determination of corporate earnings, regarding the interests corresponding to the said borrowings, which are accepted as capital, and foreign currency borrowings. In parallel with this, the part of the positive exchange rate differences that arise as a result of the decrease in exchange rates, which corresponds to the thin capitalization, should not be taken into account as foreign exchange profit in determining the corporate income. The purpose of this study is to evaluate the foreign exchange borrowings and exchange differences obtained from partners or related parties in order to meet the financing needs of institutions within the thin capitalization. [ABSTRACT FROM AUTHOR]