297 TAX LAW who prepared the agreement and the taxpayers who are the parties to the agreement. Within this context, this Newsletter will first review regulations related to the Stamp Tax Law and then go on to examine the opinions of the Turkish Revenue Administration presented in tax rulings between 2019 and 2021. Main Regulations of the STL In terms of stamp duty, pursuant to Article 1 of the Stamp Tax Code (“STC”), “the event giving rise to tax” shall occur on the condition that there is a document indicated in Table (1) attached to the STC, and that this document has been drawn up by setting thereon a signature, that it may be produced in order to prove or designate anything. Therefore, the main subject of the stamp tax is the “paper” -- not the legal transaction. Paper types included in list number 1, attached to the STL, will be subject to stamp tax. As agreements are included in list 1, they are subject to the stamp tax. List number 2, attached to the Law lists papers exempted from stamp tax. Pursuant to Article 10 of the STC, stamp duty is collected in the form of ad valorem duty or fixed duty. In the case of ad valorem duty, stamp tax is calculated upon the amount indicated in the document according to the kind and nature of the document, and, in the event of fixed duty, according to the nature of the document. In the form of ad valorem duty, it is necessary to consider whether or not the document contains a certain amount of money and if there is a certain amount or an amount which can be calculated, the amount must be subject to ad valorem tax. A certain amount of money can be determined if the amount of the transaction is denominated clearly on the document or if not denominated, it can be calculated indirectly. If several contracts and transactions entirely different from each other are indicated in the same documents, each of these contacts and transactions shall be separately subject to stamp duty. Article 6 of the STC states that in cases where contracts are bound to each other and
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