According to Article 1 and 2 of the Corporate Income Tax Code
(CIT Code) (Law No. 5520) (published in the Official Gazette dated
June 21 2006, No. 26205), corporations are among the corporate
income tax taxpayers, and both the funds established in Turkey (the
Turkish funds) and the funds established in other jurisdictions
(the foreign funds), which resemble to the Turkish funds subject to
the regulation and supervision of the Capital Market Board, are
deemed as corporation in the scope of the CIT Code. Therefore, the
income of the Turkish funds and the ones of foreign funds derived
in Turkey are subject to corporate income tax. However, until June
15 2012, the taxation of the Turkish funds and the foreign funds
are differentiated by only providing exemptions to the Turkish
funds. According to Article 5/1- d of the CIT Code, the income of
the below stated Turkish funds are exempt from corporate income tax
with a number of conditions: