EFFICIENCY AND THE RISK OF ABUSE IN TAX DISPUTE RESOLUTION IN TÜRKIYE: A COMPARATIVE ANALYSIS AND REFORM PROPOSALS

This study analyzes inefficiencies and abuse-related issues in Türkiye’s tax dispute resolution system through a comparative institutional analysis of Australia, Canada, Germany, the United Kingdom, and the Netherlands. Using IMF, OECD, and World Bank data, it finds that despite technological infrastructure, the system functions as a “bargaining and discount” arena rather than a rights-based mechanism due to limited human capital depth and weak independent oversight. A declining audit success rate (28.5%) and high physical contact level (59.3%) indicate risks of moral hazard and administrative dependence. The study proposes structural reforms including an independent tax ombudsman, mandatory internal review procedures, and e-settlement mechanisms. Focusing on 2018-2023 and non-judicial dispute resolution pathways, it identifies a shift from rights-based adjudication toward negotiated outcomes. The study offers a reform roadmap to transform the system from a conflict-oriented model into a cooperation-based structure grounded in trust and procedural justice.