AS A TAX SECURITY MEASURE EARNING OF CONTROLLED FOREING CORPORATION AND EXAMINING OF THE IMPLEMENTATION IN TERM OF TURKEY-NETHERLANDS AVOIDANCE OF DOUBLE TAXATION TREATY

It is based on the declaration of taxpayers foundation of modern tax system. Both external audits and control mechanisms built into system to check the correctness of the declaration of the taxpayer is located. That are built into this system is called tax security measures. Tax security measures taking shape and are diversified in accordance with their terms and conditions of each country. States to conflicts of tax-raising power between them Avoidance of Double Taxation Treaty are signed. On the basis of this agreement, although there be a conflict of tax-raising power prevention of harmful tax competition is another object. In this context implementation of Earning of Controlled Foreign Corporation is a tax security measure. The topic of this study, using earning of controlled foreign Corporation as a tax security measure and in this direction is to examine the implementation of the avoidance of double taxation treaty between Turkey and the Netherlands.