VERGİ AFLARINDA VERGİ BORCUNU SONA ERDİREN BİR SEBEP OLARAK “YENİLEME”

Abstract

Considering the tax amnesty regulations regarding tax debts in our country, it is seen that although the concept of withdrawal is generally used to express the termination of existing tax debts, different reasons for termination without waiver are included in terms of legal characteristics. For this reason, it is necessary to focus on the legal characterization, functioning and consequences of the reasons for the termination of the tax debt arising within the scope of tax amnesty.In the tax amnesty regulations, one of the reasons for expiration of taxes although not specified - is the reason for ‘‘renewal’’; which is the elimination of the effect of the old administrative transaction (the old debt) with a new administrative transaction (new debt) introduced in the structuring context. Many unique rules of renewal in private law can be interpreted within the framework of specific rules of tax law, and “tax renewal” can be evaluated as a reason for the termination of tax debts.The effects of the consequences of not performing the debt due to the renewal on the old transaction (debt), the statute of limitations and its accessories need to be put forward. Termination of renewal tax debt in tax should be considered as a specific reason for termination, although there are similar aspects to various reasons.