Date: 04.08.2017
Number: 62030549-125[5-2015/171]-235831
Subject: Whether the non-deductible carried-over investment allowance due to non-taxable income can be deducted from income-generating profits.
The inquiry concerns a company engaged in tugboat operations, registered in the Turkish International Ship Registry (TUGS). Two tugboats manufactured under an investment incentive certificate were registered with TUGS, and the company has a carried-over investment allowance of 761,181.07 TL from 2014. The company sought clarification on whether this carried-over allowance could be deducted from non-exempt corporate earnings, as income from TUGS-registered tugboat operations is exempt from corporate tax.
According to the relevant articles of the Income Tax Law and subsequent constitutional court decisions, the investment allowance obtained due to investment incentive certificates issued prior to April 24, 2003, ca
Source: Revenue Administration
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n be deducted from taxable corporate income. Thus, the company can deduct its investment allowance amount from its taxable corporate profits.
