EXPORT OF FINANCIAL SERVICES WITHIN İSTANBUL FINANCIAL CENTER

Abstract

The provisions governing the management and operation of İstanbul Financial Center, as well as the activities conducted within and the incentives, discounts, exemptions, and exceptions related to these activities, are regulated by İstanbul Financial Center Law numbered 7412, and the İstanbul Financial Center Regulation, which outlines the procedures and principles for implementing the law. İstanbul Financial Center Law defines financial institutions and financial service exports, and establishes exemptions, discounts on taxes and other financial obligations applicable to financial institutions engaged in activities classified as financial service exports. The details of these matters, as regulated by the law and the regulation, constitute the subject of our study.

Keywords: Finance, Istanbul Financial Center, Export of Financial Services, Exemption, Exception, Financial Activities

I. INTRODUCTION

With İstanbul Financial Center (“IFC”), it is aimed to increase financial competitiveness on the international stage, contribute to the development and deepening of financial markets, products, and services, strengthen its integration with international financial and capital markets, and thus make IFC one of the leading global financial centers.

IFC aims to bring together a wide range of financial institutions and organizations, including banks, capital market institutions, participation finance companies, financial investment and portfolio management companies, and insurance companies, under a single platform. It seeks to promote sustainable and participatory approaches to all financial services, particularly in the field of international trade. IFC aims to enhance financial development by uniting local and global financial institutions. In this context, advantages such as tax reductions, exemptions and transaction facilities granted to institutions exporting financial services make IFC an attractive option on the international stage.

II. PRINCIPLES FOR RESPONSIBLE MANAGEMENT AND IMPLEMENTATION RECOMMENDATIONS

İstanbul Financial Center Law numbered 74121 (“Law“) and the İstanbul Financial Center Regulation2 (“Regulation“) mainly regulate the procedures and principles regarding the management and operation of IFC, application for certificate of participation (“Certificate“), issuance and cancellation of Certificate, leasing of the properties in IFC and various exemptions and advantages.

To benefit from the exemptions and other tax advantages outlined in Law, participants must obtain Certificate and operate within IFC office area. The Finance Office of the Presidency of the Republic of Türkiye (“Finance Office“) is authorized and responsible for evaluating Certificate applications, issuing Certificates to eligible applicants, rejecting ineligible applications, and suspending or canceling Certificates. Participants wishing to operate within IFC office area must apply to Finance Office. The application process is conducted electronically via IFC portal, which is established and managed by Finance Office.

Law stipulates that a “One-stop Bureau” shall be established to involve relevant departments of public organizations and institutions. This bureau aims to facilitate applications such as permits, licenses, approvals related to participants’ activities, as well as permits and approvals for their employees and dependents3. Once the participants complete the application process and obtain Certificate, they will be eligible to benefit from discounts, exemptions, and other tax advantages stipulated by Law and Regulation.

III. FINANCIAL INSTITUTIONS AND THE EXPORT OF FINANCIAL SERVICES IN IFC

According to Law, financial institutions eligible to operate within IFC include legal entities engaged in financial activities, their branches, liaison offices, representative offices and sovereign wealth funds4. Central Bank of the Republic of Türkiye, regulatory and supervisory institutions, banking and non-banking finance institutions, capital market institutions, financial investment firms and portfolio management companies operate within IFC5.

Financial services offered by organizations holding Certificate, provided that the services are ultimately utilized abroad by non-residents, are considered as financial service export6. Additionally, it is stipulated that derivative transactions conducted on their own behalf and account, acquisition or disposal of assets in their portfolios, and activities, services, and transactions transferring domestic residents’ savings abroad by financial institutions, shall not be considered as financial service exports.

Article 2 of Law defines the transactions eligible for financial services exports as “financial activities” and specifies these activities, services and transactions by reference to the relevant legislation:

• Purchase and sale of foreign exchange, coins, stocks, bonds, precious metals, precious stones and all kinds of goods and assets containing these materials, as well as commercial bills and payment instruments within the scope of Protection of the Value of Turkish Currency Law numbered 15677,

• Activities of pension companies, transactions of pension mutual funds and brokerage services under the Private Pension Savings and Investment System Law numbered 46328,

• Activities of deposit banks, participation banks, development and investment banks, banks established under special laws, and financial holding companies regulated by the Banking Law numbered 54119,

• Operations of entities establishing card systems, issuing cards and entering into merchant agreements under the Bank Cards and Credit Cards Law numbered 546410,

• Activities of insurance and reinsurance companies, intermediaries, actuaries and insurance experts operating in Türkiye in line with the Insurance Law numbered 568411,

• Activities of financial leasing, factoring, financing, and savings finance companies under the Financial Leasing, Factoring, Financing, and Savings Finance Companies Law numbered 636112,

• Issuance and public offering of capital market instruments, capital market activities, stock exchange transactions under the Capital Markets Law numbered 636213,

• Activities of payment institutions, electronic money institutions, and operations of payment services, payment, and securities settlement systems under the Payment and Securities Settlement Systems, Payment Services, and Electronic Money Institutions Law numbered 649314.

IV. ADVANTAGES PROVIDED TO FINANCIAL INSTITUTIONS EXPORTING FINANCIAL SERVICES

IFC participants benefit from various exemptions and advantages under Law. Many of these benefits are exclusive to financial institutions engaged in the export of financial services as defined by the Law.

A. Tax and Financial Liability Exemptions and Discounts

1. Corporate Tax Base Reduction

Provided that they are separately reported on the corporate tax return, 75% of the earnings obtained within the scope of financial service export activities will be deducted from the corporate income when determining the corporate tax base15. To encourage financial institutions to relocate to the IFC, this deduction rate will be applied at 100% for corporate earnings during the taxation periods from 2022 to 203116.

Additionally, pursuant to Article 10 of the Corporate Tax Law numbered 552017, institutions operating in IFC area and holding Certificate are entitled to deduct 50% of the income generated from the sale of goods purchased abroad without bringing them into Türkiye, or from intermediating in transactions involving the purchase and sale of goods abroad18. This deduction applies to the determination of the corporate tax base, provided that such income is separately reported in the corporate tax return. To benefit from this deduction, the income must be transferred to Türkiye by the deadline for filing the annual corporate tax return for the relevant fiscal period, and neither the seller nor the buyer involved in the intermediary transactions may be based in Türkiye.

2. Banking and Insurance Transactions Tax Exemption

Financial institutions that have obtained Certificate are exempt from bank and insurance transaction tax in terms of financial service export transactions and the profits derived from these transactions19.

3. Stamp Duty and Fee Exemption

Transactions related to financial service export activities conducted in IFC by financial institutions that have obtained Certificate are exempt from all kinds of fees, and the papers issued in relation to these transactions are exempt from stamp duty20.

Additionally, transactions concerning the leasing of immovable properties in IFC are also exempt from all kinds of fees, and the papers issued in relation to these transactions are exempt from stamp duty21.

Furthermore, financial activity fees, which collected from the headquarters and branches of financial institutions holding Certificate in IFC in accordance with the Fees Law numbered 49222, will not be collected for a period of five years starting from 28.06.2022, the effective date of Law23.

4. Income Tax Exemption on Employee Salaries

The net monthly salary paid to personnel employed by financial institutions holding Certificate is exempt from income tax as follows: %60 for personnel with a minimum of five years of professional experience abroad, and 80% for personnel with a minimum of ten years of professional experience abroad. This exemption is applicable to the salary income of personnel who have not worked in Türkiye during the three years preceding their employment at IFC24.

B. Choice of Law

Within the scope of the activities conducted at IFC, participants at IFC have the freedom to select the governing law for any transactions and contracts subject to private law, provided that such activities do not violate the legislation applicable to the participants25.

C. Bookkeeping in Foreign Currency and Language

Notwithstanding the provisions of the Turkish Commercial Code numbered 610226 and Tax Procedure Law numbered 21327, the Ministry of Treasury and Finance is authorized to regulate the participants to keep and issue their books and documents in foreign currency28.

Participants are not obliged to keep their transactions, contracts, letters of undertaking and account books in Turkish29.

Furthermore, Law stipulates that exceptions concerning bookkeeping in foreign currencies and languages, as well as the choice of law, shall also apply to regional treasury and financial management centers of participants operating actively in at least three countries30.

D. Employment of Foreign Personnel

Participants operating in IFC are permitted to employ foreign nationals who hold work permits issued by the Ministry of Labor and Social Security. The work permit applications for these individuals will be considered exceptional under Article 16 of the International Labor Law numbered 673531. During the application and evaluation process, certain exceptions under the mentioned law may be granted for the foreign employee32 such as exception from five to one rule.

V. CONCLUSION

IFC offers a range of advantages and exemptions that make it highly attractive for financial institutions to operate within the center. These benefits include tax incentives such as discounts on the corporate tax base, exemptions from banking and insurance transaction taxes, and exemptions from stamp duty and fees. Additionally, regulations provide further conveniences, such as income tax exemptions on employee salaries, the option to choose applicable law, and the ability to maintain bookkeeping in foreign currencies and languages. These comprehensive facilities position IFC as a global hub for financial institutions and represent a significant step towards enhancing Türkiye’s competitiveness in the international financial arena.

References

  1. Official Gazette (“OG”) dated 28.06.2022 and numbered 31880 ↩︎
  2. OG dated 07.07.2023 and numbered 32241 ↩︎
  3. Article 4 of Law ↩︎
  4. Article 2 of Law ↩︎
  5. Presidency of the Republic of Türkiye, About the Istanbul Financial Center (Access Date: 17.12.2024)
    https://www.cbfo.gov.tr/en/about-istanbul-financial-center ↩︎
  6. Article 5 of Law ↩︎
  7. OG dated 25.02.1930 and numbered 1433 ↩︎
  8. OG dated 07.04.2001 and numbered 24366 ↩︎
  9. OG dated 01.11.2005 and numbered 25983 ↩︎
  10. OG dated 01.03.2006 and numbered 26095 ↩︎
  11. OG dated 14.06.2007 and numbered 26552 ↩︎
  12. OG dated 13.12.2012 and numbered 28496 ↩︎
  13. OG dated 30.12.2012 and numbered 28513 ↩︎
  14. OG dated 27.06.2013 and numbered 28690 ↩︎
  15. Subparagraph (a) of Paragraph 1 of Article 6 of Law ↩︎
  16. Provisional Article 1 of Law ↩︎
  17. OG dated 21.06.2006 and numbered 26205 ↩︎
  18. Article 10 of Corporate Tax Law ↩︎
  19. Subparagraph (b) of Paragraph 1 of Article 6 of Law ↩︎
  20. Subparagraph (c) of Paragraph 1 of Article 6 of Law ↩︎
  21. Paragraph 3 of Article 6 of Law ↩︎
  22. OG dated 17.07.1964 and numbered 11756 ↩︎
  23. Provisional Article 1 of Law ↩︎
  24. Paragraph 2 of Article 6 of Law ↩︎
  25. Paragraph 3 of Article 7 of Law ↩︎
  26. OG dated 14.02.2011 and numbered 27846 ↩︎
  27. OG dated 10.01.1961 and numbered 10703 ↩︎
  28. Paragraph 1 of Article 7 of Law ↩︎
  29. Paragraph 2 of Article 7 of Law ↩︎
  30. Paragraph 4 of Article 6 and Paragraph 4 of Article 7 of Law ↩︎
  31. OG dated 13.08.2016 and numbered 29800 ↩︎
  32. Paragraph 1 of Article 8 of Law ↩︎
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THE APPLICATION OF THE PROHIBITION ON CONTRACTING IN FOREIGN CURRENCY IN WORK CONTRACTS UNDER DECREE NO. 32 ON THE PROTECTION OF THE VALUE OF TURKISH CURRENCY

Abstract

The prohibition on contracting in foreign currency refers to the regulation that prohibits the determination of payment obligations arising from a contractual relationship in foreign currency or foreign currency-indexed. Whereas, the primary legal basis for the prohibition on contracting in foreign currency is Law No. 1567 on the Protection of the Value of Turkish Currency (“Law No. 1567”)1, the regulations regarding this prohibition are set forth under Decree No. 32 on the Protection of the Value of  Turkish Currency, dated 07.08.1989 (“Decree No. 32”)2, and the Communiqué No. 2008-32/34 on Decree No. 32 on the Protection of the Value of  Turkish Currency (“Communiqué on Decree No. 32”)3, issued by the Ministry of Treasury and Finance (“Ministry”) pursuant to Decree No. 32. In this study, first of all, a brief overview of the legal regulations concerning the prohibition on contracting in foreign currency will be provided. After addressing the legal basis and scope of the prohibition on contracting in foreign currency, this prohibition will be analyzed within the context of work contracts. Then, exceptions to the prohibition applicable to work contracts will be examined, and finally, the legal consequences of non-compliance with the prohibition will be discussed.

Keywords: Decree No. 32, Communiqué on Decree No. 32, Work Contract, Payment Obligation, Foreign Currency, Foreign Currency-Indexed, Prohibition, Exception

I. INTRODUCTION

With Presidential Decree No. 85 and dated 12.09.2018 on Amendments to Decree No. 32 on the Protection of the Value of Turkish Currency (“Decree No. 85”)4, an additional subparagraph (g) was added to Article 4 of Decree No. 32, and it was stipulated that, except in cases specified by the Ministry, residents in Türkiye are prohibited from agreeing to set the contract price and other payment obligations arising from contracts, including contracts for the purchase and sale of movable and immovable property, transportation and financial leasing, as well as any lease, employment, service, and work contracts, in foreign currency or foreign currency-indexed (prohibition on contracting in foreign currency). The prohibition on contracting in foreign currency applies solely to the types of contracts listed in the relevant article. The focus of this study is the examination of the application of this prohibition in relation to work contracts, as regulated under Articles 470 to 486 of the Turkish Code of Obligations No. 6098 (“TCO”)5.

II. LEGAL REGULATIONS REGARDING THE PROHIBITION ON CONTRACTING IN FOREIGN CURRENCY

In order to establish the procedures and principles for the implementation of  Decree No. 85, which forms the primary basis for the prohibition on contracting in foreign currency, the Ministry initially issued the Communiqué on Amendments to Communiqué No. 2008-32/34 on Decree No. 32 on the Protection of the Value of Turkish Currency (“Communiqué No. 2018-32/51“)6, and the cancelled Article 8 of the Communiqué on Decree No. 32 was rearranged under the title “Foreign Currency and Foreign Currency-Indexed Contracts“. However, as the regulations introduced by Communiqué No. 2018-32/51 proved insufficient in resolving uncertainties regarding the implementation of Decree No. 85, the Ministry issued the Communiqué on Amendments to Communiqué No. 2008-32/34 on Decree No. 32 on the Protection of the Value of the Turkish Currency (“Communiqué No. 2018-32/52“)7. With the Communiqué No. 2018-32/52, the Article 8 of the Communiqué on Decree No. 32 was amended again, the scope of the prohibition was determined more clearly and the exceptions to the prohibition on contracting in foreign currency under Decree No. 85 were regulated.

In order to clarify the questions arising from the implementation of Decree No. 85 and the secondary regulations issued pursuant to it, and to resolve the uncertainties that have emerged, the Ministry issued announcements titled “Frequently Asked Questions” on 12.10.2018, 16.10.2018, and finally on 27.02.2019, which were published on the Ministry’s website.8

Since the publication of Communiqué No. 2018-32/52 until today, legal regulations enacted by the Ministry have resulted in occasional amendments to Article 8 of the Communiqué on Decree No. 32, however, no additional obligation or exception has been introduced regarding the determination of payment obligations in work contracts in foreign currency or indexed to foreign currency. Therefore, the subsequent amendments to the Communiqué on Decree No. 32 are not included in this study.

III. EVALUATIONS REGARDING THE PROHIBITION ON CONTRACTING IN FOREIGN CURRENCY INTRODUCED BY DECREE NO. 85

The subparagraph (g) added to Article 4 of Decree No. 32 by Decree No. 85 only imposes restrictions on contracting in foreign currency for specific types of contracts to be executed between individuals residing in Türkiye. Therefore, contracts in which one of the parties is located abroad fall outside the scope of the provision of the relevant article.

For the purposes of the relevant provision, individuals residing in Türkiye include Turkish citizens working abroad as employees, freelancers, or independent contractors, as well as natural and legal persons who have their legal domicile in Türkiye.9 In other words, natural persons who do not have citizenship ties with the Republic of Türkiye but have their legal domicile in Türkiye, as well as legal entities with their legal domicile in Türkiye, are included within the scope of this regulation and are considered as residents in Türkiye for the purposes of the application of the relevant legal provisions. Additionally, the branches, representative offices, offices, liaison offices, funds operated or managed by persons residing in Türkiye abroad, as well as companies in which they hold directly or indirectly fifty percent or more of the shares, are considered as residents in Türkiye for the application of subparagraph (g) of Article 4 of Decree No. 32. However, this provision does not apply if the contract is executed abroad.10

Pursuant to the Communiqué on Decree No. 32, contracts indexed to precious metals and/or commodities priced in foreign currency on international markets and/or indirectly indexed to foreign currency are considered foreign currency-indexed contracts in terms of the application of subparagraph (g) of Article 4 of Decree No. 32.11

The regulation introduced by Article 4(g) of Decree No. 32 stipulates that not only the contract price specified in the contracts listed in Decree No. 32, but also any other payment obligations arising from the contracts cannot be agreed upon in foreign currency or indexed to foreign currency. Accordingly, this regulation encompasses any interest, late payment penalties, liquidated damages, and any other compensation obligations applicable to the contract price specified in the contracts.

Additionally, pursuant to Article 8 of the Communiqué on Decree No. 32, it is not possible for the amounts included in the negotiable instruments issued under contracts, where the contract price and other payment obligations arising from such contracts cannot be agreed upon in foreign currency or indexed to foreign currency, to be determined in foreign currency or indexed to foreign currency.12 However, negotiable instruments issued and circulated prior to the effective date of Decree No. 85, dated 13.09.2018, are exempt from the provisions of this article.

IV. FOREIGN CURRENCY PROHIBITON AND EXCEPTIONS IN THE CONTEXT OF WORK CONTRACTS

A. Regulation Regarding the Work Contract and the Exception of the Foreign Currency Prohibition in the Context of Work Contract

Under the TCO, a work contract is a contract in which the contractor undertakes to create a work, and the employer undertakes to pay a price in return. Therefore, construction and EPC contracts, contracts related to turnkey projects, or similar contracts where the personal characteristics of the contractor are significant in the creation of the work, are considered work contracts and are subject to the provisions related to work contracts under the relevant legislation.

Under regulations introduced by Communiqué No. 2018-32/51, Paragraph 5 of the rearranged Article 8 of the Communiqué on Decree No. 32 stipulated regarding work contracts that “residents in Türkiye may not agree on the contract price and other payment obligations arising from these contracts in foreign currency or indexed to foreign currency, with respect to work contracts, except for the construction, repair, and maintenance of ships defined in the Turkish International Ship Registry Law No. 4490 dated 16/12/1999 and the Law amending Decree Law No. 491.“

However, following the amendments made to the Communiqué on Decree No. 32 with the Communiqué No. 2018-32/52, the provision regarding the prohibition on work contracts was regulated in Paragraph 8 of the Article 8 of the Communiqué on Decree No. 32 as “residents in Türkiye may agree on the contract price and other payment obligations arising from such contracts in foreign currency or indexed to foreign currency in work contracts that involve costs in foreign currency.” As a result, all work contracts involving foreign currency costs have been included within the exception to the prohibition on contracting in foreign currency and the exception regarding work contracts has been significantly expanded.

In other words, as a general rule, it is prohibited to stipulate the contract price and other payment obligations arising from work contracts in foreign currency or indexed to foreign currency. However, where the work contract involves a cost in foreign currency, this constitutes an exception, and in such case, the contract price and other payment obligations under the work contract may be agreed upon in foreign currency or indexed to foreign currency.

Additionally, no specific percentage has been established regarding the foreign currency component that must be included in such costs. Indeed, in the response to question 6 of the information letter published on the Ministry’s website under the title “Frequently Asked Questions Within the Scope of the Communique on Decree No. 32 on the Protection of the Value of Turkish Currency (2018-32/52)”13, it has been stated that it is not necessary for the work contract to contain a foreign currency cost above a certain percentage in order for the prohibition on contracting in foreign currency not to be applied, and that it is sufficient for a portion of the costs to be denominated in foreign currency for the contract price and other payment obligations arising from such contracts to be agreed upon in foreign currency or indexed to foreign currency.

B. General Exceptions Applicable to Work Contracts

Other exceptions to the prohibition on contracting in foreign currency in relation to work contracts are regulated in the other paragraphs of Article 8 of the Communiqué on Decree No. 32. In this context, within the projects to be carried out under the execution of foreign currency or foreign currency-indexed tenders, contracts, and international agreements to which public institutions and organizations are parties, it has been made possible to decide on determining the contract price and other payment obligations arising from these contracts in foreign currency or indexed to foreign currency in contracts to be concluded by contractors or responsible companies and the parties with whom they enter into contracts, or concluded within the framework of the mentioned projects, excluding real estate sales contracts and employment contracts.14

Since, the relevant paragraph only excludes real estate sale contracts and employment contracts from the scope of exceptions, the contract price and other payment obligations arising from these contracts can be decided in foreign currency or indexed to foreign currency in the work contracts to be concluded for the projects to be carried out within the scope of the execution of tenders, contracts and international agreements in foreign currency or indexed to foreign currency to which public institutions and organizations are parties.

The phrase “public institutions and organizations” mentioned in the relevant regulation refers to the institutions, administrations, and local administrations referred to in the Public Financial Management and Control Law No. 501815 as public administrations within the scope of general administration and mentioned in Annexes I, II, III and IV of the said Law, as well as companies in which these institutions and administrations directly or indirectly hold at least 50% of the ownership.

Similarly, subject to the exception for public institutions and organizations, another paragraph of Article 8 of the Communiqué on Decree No. 32 has made it possible for contract prices and other payment obligations arising from these contracts to be determined, paid, and accepted in foreign currency or indexed to foreign currency in contracts other than real estate sales and real estate rentals to which public institutions and organizations or Turkish Armed Forces Foundation companies are parties.16 The companies referred to as the Turkish Armed Forces Foundation companies are those whose capital is at least fifty percent directly or indirectly owned by the Turkish Armed Forces Foundation, established to strengthen the Turkish Armed Forces, such as ASELSAN, HAVELSAN, and ROKETSAN. Therefore, there is no impediment to the contract price and other payment obligations arising from these contracts being determined in foreign currency or indexed to foreign currency, in terms of the work contracts to which the companies in question are parties.

V. SANCTIONS

Within the scope of the hierarchy of norms, in case of non-compliance with the regulations included in the Communiqué on Decision No. 32, an administrative fine is imposed separately for each party to the contract under Paragraph 1 of Article 3 of Law No. 1567. The amounts specified in the relevant article of Law No. 1567 are the amounts determined by the amendment made to the said Law in 2008, and these amounts are updated every year by taking into account the revaluation rates per Paragraph 7 of Article 17 of Law No. 5326 on Misdemeanors.17 In the case of recurrence, these fines are applied at twice the amount. However, in order to initiate proceedings before the Chief Public Prosecutor’s Office regarding violations of the Communique on Decree No. 32, the notifications sent to the Ministry must include concrete information and supporting documents (invoices, contract samples, price offers, etc.) to substantiate the claims. No action is taken by the Ministry on notifications that are not based on any concrete documents.

VI. CONCLUSION

With subparagraph (g) added to Article 4 of Decision No. 32 by Decision No. 85 and the secondary regulations issued by the Ministry afterward, it is aimed to ensure economic stability in Türkiye and to encourage the use of Turkish Lira in contracts involving monetary obligations of real and legal persons resident in Türkiye.

Work contracts, which are regulated in the relevant articles of the TCO, were also included in the scope of the prohibition in Decree No. 32, but the exceptions to the prohibition that can be applied to work contracts were determined with the regulations introduced later. In case even one of the exceptions in question exists, it has been made possible for the contract price in work contracts and the payment obligations arising from it to be determined in foreign currency or indexed to foreign currency.

References

  1. Official Gazette dated 25.02.1930 and numbered 1433 ↩︎
  2. Official Gazette dated 11.08.1989 and numbered 20249 ↩︎
  3. Official Gazette dated 28.02.2008 and numbered 26801 ↩︎
  4. Official Gazette dated 13.09.2018 and numbered 30534 ↩︎
  5. Official Gazette dated 04.02.2011 and numbered 27836 ↩︎
  6. Official Gazette dated 06.10.2018 and numbered 30557 ↩︎
  7. Official Gazette dated 16.11.2018 and numbered 30597 ↩︎
  8. Ercüment Özkaraca, “Türk Parası Kıymetini Koruma Hakkında 32 Sayılı Kararın İş Sözleşmelerinde Uygulama Alanı”, Marmara University Faculty of Law Journal of Legal Studies, Volume 25, Issue 1, 2019, p. 188. ↩︎
  9. Decree No. 32, article 2(b) ↩︎
  10. Communiqué on Decree No. 32, article 8/24 ↩︎
  11. Communiqué on Decree No. 32, article 8/23 ↩︎
  12. Communiqué on Decree No. 32, article 8/22 ↩︎
  13. https://www.hmb.gov.tr/finansal-piyasalar-ve-kambiyo-sikca-sorulan-sorular ↩︎
  14. Communiqué on Decree No. 32, article 8/16 ↩︎
  15. Official Gazette dated 24.12.2003 and numbered 25326 ↩︎
  16. Communiqué on Decree No. 32, article 8/15 ↩︎
  17. Official Gazette dated 31.03.2005 and numbered 25772 (repeating) ↩︎
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