In an Invitation to Explain, Symmetry in a Bank Account Cannot Be Treated as Income

Istanbul 13th Tax Court, 09.04.2026

The most dangerous inference in tax law is to believe that figures speak for themselves. In 2023, TRY 2,887,200 had entered my client’s bank account and TRY 2,886,958 had left it for the purchase of a vehicle. The administration looked at this symmetry and concluded that there was undeclared income; it invited my client to explain a difference in the tax base of TRY 3,574,605.32, found the explanation insufficient and assessed income tax of TRY 1,286,706.29.

In the file, however, the silence of the figures gave way to a different story. TRY 264,000 of the inflows were transfers between the client’s own accounts; of the rest, part was money borrowed from relatives, part was gold sold for the purchase of the vehicle, and part consisted of transfers from third parties that could not be linked to any business activity. Despite two separate interim orders of the court, the administration could not show how it had reached the difference in the tax base. The court accepted the claim and annulled the transaction.

The invitation to explain is a bouquet of flowers extended to the taxpayer. Once the taxpayer has explained, it is the administration’s turn to speak; it should not point at the bank statement and say “there is the income”, it should have to show the nature of each figure and its causal link with the business. Otherwise the institution loses the invitation in its name and turns into a collection template.