New Legal Arrangements In The Restructuring Of Tax Liabilities

New Legal Arrangements In The Restructuring Of Tax Liabilities

ERDEMİR&ÖZMEN ATTORNEY PARTNERSHIP

2020

“The Law on the Restructuring of Certain Receivables and Amendments to Certain Laws (“the Law”)” has entered into force as published in the Official Gazette dated 17.11.2020. The provisions regarding restructuring of certain receivables and the receivables which became final and are included in the article 1 of the Law and the provisions regarding amendments to certain laws constitute the subject of the Law.  

This newsletter has been prepared in order to furnish information about the tax structuring under the aforementioned Law.

Structuring of the receivables which became final

According to the article 2 of the Law, it is prescribed that, among the receivables pursued by the collection offices affiliated with the Ministry of Treasury and Finance, the provincial special administrations and the municipalities, by the publication date of the Law, the collection of the following shall be waived:

a) The whole tax penalties issued dependently on the principal, including those whose principals were paid prior to the publication date of the Law, and the whole late fees dependent on these penalties, and the accessory public receivables such as late fees and default interests dependent on taxes, provided that they are entirely paid in the way and within the period specified by the Law, of the amount to be calculated by taking the domestic producer price index (“D-PPI”) monthly rates of change as the basis until the publication date of the Law, instead of the whole unpaid portion of the taxes whose payment periods have not elapsed yet or which have not been paid though they became due and the accessory public receivables appurtenant thereto; of the amount to be calculated by taking the D-PPI monthly rates of change as the basis in case the unpaid receivable consists of only the accessory receivable;  

b) The remaining 50% of the penalties provided that they are entirely paid in the way and within the period specified by the Law and the whole late fees dependent on these penalties, for the amount to be calculated by taking the D-PPI monthly rates of change as the basis instead of late fee in case the unpaid receivable consists of only late fee; of the amount to be calculated by taking the D-PPI monthly rates of change as the basis until the publication date of the Law, instead of the late fee to such amount and 50% of the tax penalties issued due to participation and the tax penalties which have been issued not dependently on the principal of a tax and whose payment periods have not elapsed yet or which have not been paid though they became due;

c) The whole accessories subject to penalty provided that they are entirely paid in the way and within the period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis instead of the accessory receivable in case the unpaid receivable consists of only accessory receivable; of the amount to be calculated by taking the D-PPI monthly rates of change as the basis until the publication date of the Law, instead of the appurtenant accessory public receivables and the whole administrative fines whose payment periods have not elapsed yet or which have not been paid though they became due and which are included in the scope of the subclause (2) of the subparagraph (a) of the first paragraph of the article 1 (“the administrative fines issued prior to 31/8/2020 (including that date) (“with the exclusion of the administrative fines issued by the regulatory and supervisory authorities referred to in the table (III) enclosed with the Public Financial Management and Control Law dated 10.12.2003 and numbered 5018 and the administrative fines issued as per the Law on the Prevention and Control of Hazards of Tobacco Products, i.e. the Law dated 07.01.1996 and numbered 4207, and the General Hygiene Law dated 24/4/1930 and numbered 1593)” art. 1/1-a.2); and

ç) The whole accessory public receivables such as interest, penal interest, default interest, late fee applied, provided that they are entirely paid in the way and within the period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis instead of the accessory receivable in case the unpaid receivable consists of only accessory receivable; of the amount to be calculated by taking the D-PPI monthly rates of change as the basis until the publication date of the Law, instead of the accessory public receivables appurtenant to these receivables and the whole unpaid portion of the principal public receivables whose payment periods have not elapsed yet or which have not been paid though they became due and which fall outside the above subclauses.

Furthermore, in the paragraph 2 of the same provision, it is prescribed that, among the receivables pursued by the collection offices affiliated with the Ministry of Trade, by the publication date of the Law, the collection of the following shall be waived:

a) The whole administrative fines issued dependently on the principal, including those whose principals were paid prior to the publication date of the Law, and the accessory public receivables, such as interest, default interest, late fee, dependent on customs duties, provided that they are entirely paid in the way and within the period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis instead of the accessory receivable in case the unpaid receivable consists of only accessory receivable; of the amount to be calculated by taking the D-PPI monthly rates of change as the basis until the publication date of the Law, instead of the accessory public receivables appurtenant to these receivables and the whole unpaid portion of the customs duties whose payment periods have not elapsed yet or which have not been paid though they became due; and

b) 50% of the administrative fines issued due to the participation provisions of the Misdemeanor Law dated 30.03.2005 and numbered 5326 and the administrative fines which were issued not dependently on the principals of customs duties due to a customs liability within the scope of the Law numbered 4458 and other relevant laws and whose payment periods have not elapsed yet or which have not been paid though they became due, and the remaining 50% of the fines provided that they are paid in the way and within the period specified by the Law.

The subparagraph (b) of the paragraph (3) contained in the article 2 emphasizes that, among the taxes whose tax return submission periods and payment periods are postponed as per the article 15 of the Law numbered 213 by the publication date of the Law though they are related to the periods included in the scope of the Law, the provisions of the said Law shall not apply to those whose last day of the payment period is determined to correspond to October, November or December 2020.  

The paragraph (5) of the article 2 of the Law prescribes that it is mandatory to pay the whole amount to be calculated by taking the D-PPI monthly rates of change as the basis until the publication date of the Law instead of the special consumption tax which is structured within the scope of the Law and which became due after 01.03.2016 and is related to the products contained in the tables (A) and (B) of the list (III) enclosed with the Special Consumption Tax Law dated 06.06.2002 and numbered 4760 and the stamp tax arising from the tax returns pertaining to this tax and the default interest and late fee dependent on these taxes, in order to allow the producers and importers of tobacco products, macarons, leaf cigarette papers and alcoholic beverages to use the specific labels and signs for which the obligation to use is introduced within the scope of the authorization granted to the Ministry of Treasury and Finance by the subparagraph (6) of the paragraph 1 of the article 257 bis contained in the Law numbered 213.

According to the paragraph (6) of the article 2 contained in the Law; for the receivables which pertain to the periods covered by the said Law and in respect of which the written notice for payment could not be served on the obligor though they became final under a judicial decision by the publication date of the Law, these receivables shall also be structured within the scope of the relevant article provided that the application is submitted by the obligors in the way and within the period prescribed by the Law. For the receivables included in the scope of the said article, a written notification shall not additionally be served and the publication date of the Law shall be deemed to be the due date of the receivables. In case the amounts structured within this scope are not paid in the way and within the period prescribed by the Law, the due date shall remain unchanged.

The paragraph (7) of the same article prescribes that, among the water, waste water and solid waste fee receivables and the receivables necessary to be collected as per the article 97 of the Law numbered 2464, in case of payment, within the framework of the provisions contained in the same paragraph, of the amounts determined in result of the calculations to be carried out in accordance with the provisions of the subparagraph (ç) of the first paragraph of the article about the appurtenant accessories and those not paid by the publication date of the Law though their due date is prior to 31.08.2020, the collection of the accessories and the penalties appurtenant to these receivables shall be waived.

The paragraph (8) of the article 2 contained in the Law emphasizes that in case of payment, within the framework of the provisions contained in the same paragraph, of the amounts determined in result of the calculations to be carried out in accordance with the provisions of the subparagraph (ç) of the first paragraph contained in the article 2 about the appurtenant accessories and the metropolitan municipalities’ whole solid waste fee receivable principals which were not paid by the publication date of the Law though their due date is prior to 31.08.2020 as per the article 11 of the Law numbered 2872, the collection of the accessories and the penalties appurtenant to these receivables shall be waived.

The paragraph (9) of the same article prescribes that, in case of payment, within the framework of the provisions contained in the same paragraph, of the amounts determined in result of the calculations to be carried out in accordance with the provisions of the subparagraph (ç) of the first paragraph contained in the article 2 about the appurtenant accessories and the metropolitan municipalities water and sewerage administrations’ whole water and waste water fee receivable principals which were not paid by the publication date of the Law though their due date is prior to 31.08.2020 within the scope of the Law numbered 2560, the collection of the accessories such as default interest, late fee and the penalties appurtenant to these receivables shall be waived.

According to the paragraph (11) of the article 2 contained in the Law;

It is prescribed that, among the receivables pursued by the collection offices affiliated with the Social Security Institution i.e. with regard to the following receivables which pertain to August 2020 and the months prior to August 2020 and were not paid by the publication date of the Law though they accrued prior to the publication date of the Law, in case of payment, in the way and within the period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis for the period elapsed until the publication date of the Law from the expiration dates of the payment periods for the following receivables and the principals of the following receivables:  

a) The insurance premiums, contributions towards pension and provision for the institution, unemployment insurance premiums, social security support contributions, arising from the statuses of being covered by insurance within the scope of the subparagraph (a), (b) and (c) of the first paragraph contained in the article 4 of the Law numbered 5510;

b) The voluntary insurance premiums and community insurance premiums, the payment possibilities of which have not ceased to exist as per the relevant legislation by the date of the application submitted in accordance with the Law;

c) The contributions to education, the special transaction tax and the stamp tax pursued by the Social Security Institution in virtue of the relevant laws;

the collection of all of the accessory receivables such as late fee and default interest applied to these receivables shall be waived.

It is adopted that, in case of payment, in the way and within the period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis for the period elapsed until the publication date of the Law from the commencement date of the period in respect of which delay penalty and late fee are calculated for these receivables and the insurance premium principals calculated on the basis of the lacking labor cost found as a result of the preliminary assessments, investigations and determinations carried out in connection with the tender-related works and the constructions of special nature; which were not paid by the publication date of the Law although they are in connection with the tenders-related works and the constructions of special nature which have been completed until 31.08.2020 and although the relevant written notice has been served on the employer after they were accrued ex-officio by the Institution; the collection of all the accessory receivables such as delay penalty and late fee applied to these receivables shall be waived.

According to the paragraph (13) of the article 2 contained in the Law, in case of payment, in the way and within the period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis for the period elapsed until the publication date of the Law from the expiration dates of payment for such amount and 50% of the principals of the administrative fines which are related to the determinations carried out prior to 31.08.2020 and are pursued by the Institution and have not been paid by the publication date of the said Law though they became final prior to the publication date of the Law, the collection of the remaining 50% of the principals of the administrative fines and all the accessory receivables such as delay penalty and late fee applied to those administrative fines shall be waived.

It is adopted that, in cases of nonpayment, by the publication date of the Law, of the accessories of the receivables which are pursued by the collection offices affiliated with the Social Security Institution and are included in the scope of the said Law, though the principals of these receivables were paid prior to the publication date of the Law, if 40% of the accessory receivable, the principal of which was paid, is paid in the way and within the period specified by the Law, the collection of the remaining 60% shall be waived.

As regards the insured persons included in the scope of the subparagraph (b) of the paragraph 1 contained in the article 4 of the Law numbered 5510 and those that are insured within the scope of the additional article 5 and the additional article 6 of the same, the paragraph (15) of the article 2 contained in the Law prescribes that, in case these persons restructure their debts, they shall start to benefit from the general health insurance, provided that they have not more than 60 days’ premium and premium-related debts other than the restructured debt or that, though they have more than 60 days’ premium and premium-related debts, they have split these debts into installments or restructured these debts in accordance with the relevant laws and are also fulfilling their payment obligations and have paid the first installment of their debts structured as per this article.

In case of payment, until 30.04.2021, of the premium debts which pertain to August 2020 and the months prior to August 2020 and were not paid though they accrued within the scope of the article 60/1-g of the Law numbered 5510 prior to the publication date of the Law, the collection of all the relevant accessory receivables such as delay penalty and late fee shall be waived. For those that have premium debts arising from their statuses of being covered by insurance within the scope of the article 60/1-g of the Law numbered 5510 prior to the publication date of the Law, in case these persons bear the conditions specified by the article 67 of the said Law, they shall be allowed to benefit from medical and healthcare services and enjoy the other rights until 30.04.2021 from the publication date of the Law, regardless of their premium debts pertaining to the period prior to the publication date of the Law.  

It is necessary for the obligors, who wish to benefit from the provisions contained in the article 2 of the Law, to fulfill the conditions specified by the article, not to bring a relevant action, to waive of the action if there is such action brought and not to apply for legal remedies.   

Things to do to benefit from the provisions of the Law

According to the article 3 bearing the heading “Common Provisions” and contained in the Law, it is necessary for the obligors, who wish to benefit from the provisions of the Law, to:

a) submit the relevant application to the relevant administration until 31.12.2020 (including that date), and

b) pay, until 31.01.2021 (including that date), the first installment of the amounts payable to the collection offices affiliated with the Ministry of Treasury and Finance, the Ministry of Trade, the special provincial administrations, the municipalities and the Departments of Investment Monitoring and Coordination (DIMCs); and pay, until 28.02.2021 (including that date), the first installment of the amounts payable to the collection offices affiliated with the Social Security Institution, and pay the other relevant installments in maximum eighteen equal portions in two-month periods following these dates.

In the paragraph (2) of the article, it is adopted that, in case the last day of the payment period of the payable installments coincides with an official holiday, the period shall expire at the end of the working hour on the first business day following the holiday. The amounts, calculated in accordance with the provisions of the Law, may be paid in cash or in installments.

According to the article 4 of the Law;

It is prescribed that “Among the receivables which are pursued by the collection offices affiliated with the Ministry of Treasury and Finance and are included in the scope of the Law numbered 6183 and have not been paid by the publication date of the Law though they became due prior to 31.12.2014 (including that date), the collection of the principal receivables whose amounts do not exceed 100 Turkish Liras, considering the type, period, principals of each receivable separately, and of the accessory receivables appurtenant to these principals, regardless of their amount, and of those whose amounts do not exceed 200 Turkish Liras, among the accessory receivables whose principals were paid, shall be waived.” 

Furthermore, the paragraph (2) of the same article prescribes that, among the receivables which are pursued by the collection offices affiliated with the Ministry of Trade and have not been paid until the publication date of the Law though they became due prior to 31.12.2014 and which should be pursued by customs administrations within the scope of Law numbered 6183, the collection of the principal receivables whose amounts do not exceed 100 Turkish Liras, considering the type, liability, principals of each receivable separately, and of those whose amounts do not exceed 150 Turkish Liras among administrative fines, and of the accessory receivables appurtenant to these receivables, regardless of their amount, and of those which do not exceed 200 Turkish Liras in total, among the accessory receivables whose principals were paid, shall be waived.

Among the unpaid insurance premium, unemployment insurance premium, social security support contribution and administrative fine receivables which pertain to the workplaces excluded from the scope of the Law numbered 5510 and were not paid though the payment due date of the debt pertaining to the workplace is 31.12.2017 or an earlier date, the collection of the receivables whose principals do not exceed 100 Turkish Liras in total, and of their accessories such as delay penalty and late fee appurtenant to these receivables, regardless of their amount, and of those whose amounts do not exceed 200 Turkish Liras, among the accessory receivables whose principals were paid, shall be waived.  

In case of payment, in the way and within the period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis for the period elapsed until the publication date of the Law from the commencement of the period that legal interest is charged to these debts and all kinds of debts of the employers and third parties that they are obliged to pay due to the acts towards the general health insured and their dependants and the cases of occupational accident and occupational disease, disability, ordinary disability and death by virtue of the repealed article 129 contained in the Law on the Retirement Fund of the Republic of Turkey i.e. the Law dated 08.06.1949 and numbered 5434, the repealed article 63 of the Law numbered 1479 and the repealed articles 10, 26, 27 and 28 of the Social Insurance Law dated 17.07.1964 and numbered 506 and the articles 14, 21, 23, 39 and 76 of the Law numbered 5510, the collection of the legal interest charged to these debts shall be waived.  

As regards the debts which are related to incomes and salaries and in respect of which the Social Security Institution finds that they have been paid unduly or in excess and which should be collected by virtue of the article 96 contained in the Law numbered 5510 and the repealed provisions of the Law numbered 2626, the Law on Agricultural Workers’ Social Insurance i.e. the Law numbered 2925, the Law numbered 1479 and the Law numbered 506, the paragraph (5) of the same article prescribes that, in case of payment, in the way and within period specified by the Law, of the amount to be calculated by taking the D-PPI monthly rates of change as the basis for the period elapsed until the publication date of the Law from the commencement of the period that legal interest is charged to these debts and the principals of these debts, the collection of the legal interest charged to these debts shall be waived.   

According to the paragraph 6 of the article 4 contained in the Law;  

For the following which were not paid until the publication date of the Law though they should have been paid by 31.8.2020, namely:

a) All the contribution fee debts’ principals owed to the Union of Chambers and Commodity Exchanges of Turkey by the chambers and exchanges, the exchange registration fees and the chamber shares from the freight revenues and the contribution fees owed to the chambers and exchanges by their members as per the provisions of the Law on the Union of Chambers and Commodity Exchanges of Turkey and the Chambers and Commodity Exchanges i.e. the Law dated 18.05.2004 and numbered 5174, and all the insurance appraisers and insurance agencies registration contribution fee debt principals necessary to be paid to the Union of Chambers and Commodity Exchanges of Turkey pursuant to the paragraph 23 of the article 26 and the paragraph 7 of the article 27 contained in the Insurance Law dated 03.06.2007 and numbered 5684;

b) The craftsmen’s and tradesmen’s all contribution fee debt principals they owed to the chambers, of which they are the members, as per the provisions of the Law on Professional Organizations of Craftsmen and Tradesmen i.e. the Law dated 07.06.2005 and numbered 5362, and all the participation share debt principals owed by the chambers to the union and to the federations of which they are the members and by the union and federations to the Confederation of Turkish Tradesmen and Craftsmen, and all the vocational education and training development and support fund debt principals owed by tradesmen and craftsmen;

c) All the principals of the union share debts owed to the Union of Chambers of Certified Public Accountants of Turkey by the chambers and the contribution fee debts owed by the profession members to the chambers, of which they are the members, as per the provisions of the Law on Accounting Profession i.e. the Law dated 01.06.1989 and numbered 3568;

ç) The lawyers’ and law apprentices’ all bar association contribution fee and law internship credit debt principals as per the provisions of the Attorneyship Law dated 19.03.1969 and numbered 1136;

d) All the principals of the membership contribution fee debts owed by the exporters to the exporters’ associations, of which they are the members, as per the Law on the Foundation and Duties of the Turkish Exporters Assembly and the Exporters’ Associations i.e. the Law dated 18.06.2009 and numbered 5910;

in case of payment of the first installment by the end of the third month following the publication date of the Law and in case of payment of the remaining portion in monthly periods and in a maximum of six equal installments and if the receivable principals, the accessory receivables such as interest, default interest, late fee applied to these receivables were paid in whole or in part prior to the publication date of the Law, the collection of the accessory receivables such as interest, default interest, late fee corresponding to the paid debt principals shall be waived.  

e) In order to benefit from the provisions of this paragraph, it is mandatory to submit the relevant application to the obligee department or unit by the end of the second month following the publication date of the Law.

f) In case the amounts necessary to be paid within the scope of this paragraph are not paid in whole or in part in the way and within period stipulated by the paragraph, the unpaid receivable principals and the relevant accessory receivables such as interest, default interest, late fee shall be collected in accordance with the provisions of the related legislation.

g) It is mandatory for the obligors that wish to benefit from the provisions of this article to fulfill the conditions specified by the paragraph, not to bring a relevant action, to waive of the action if there is such action brought and not to apply for legal remedies. For the receivables in respect of which enforcement proceedings were initiated, including those for which an action was brought and/or a court has rendered a judgement and which became final prior to the publication date of the Law, in case the obligor submits an application in order to benefit from the provisions of this paragraph, the actions and/or enforcement proceedings shall be terminated. Within this context, the legal expenses, the expenses for enforcement proceedings and the attorneys’ fees pertaining to the fully paid receivables shall not be claimed mutually.

ğ) The legal enforcement proceedings and the procedures for deletion from the bar association plate and registry, carried out due to nonpayment of the bar association contribution fee and internship credit debts, shall be suspended by end of payment period of the installments from the month following the publication date of the Law.

h) As regards the members whose chamber/exchange registrations continue although their taxpayer statuses have ceased to exist, the provisions of this paragraph shall apply to these members’ debts unpaid by the end of the date that their tax payer statuses have ceased to exist. After the date that the taxpayer status has ceased to exist, the collection of all the relevant accessory receivables as well as the principals of the accrued contribution fee debts shall be waived.

ı) The relevant administrations are authorized to determine the principles and procedures regarding the implementation of this paragraph.

Provided that the amount, which shall be calculated by taking the D-PPI monthly rates of change until the publication date of the Law instead of these receivables’ accessories such as late fee, interest and all the usage fees and revenue shares principals, not paid by the publication date of the Law though they became due by 31.08.2020 and arising from the sales, easement and leasing transactions carried out about their owned real estates by provincial special administrations, municipalities and affiliated entities and the companies in which they hold capital at a rate more than 50%, is entirely paid in a maximum of eighteen equal installments in two-month periods starting from the third month following the publication date of the Law, coupled with the coefficient calculated in accordance with the provisions of the subparagraph (ç) of the paragraph 3 contained in the article 3, the collection of the accessory receivables such as late fee, interest calculated for these receivables shall be waived. However, in order to benefit from the provisions of the said paragraph; it is, as per the paragraph 9 of the article 4, mandatory not to bring a relevant action and to waive of the action if there is such action brought.  

As regards the rents which arise from the leasing transactions pertaining to the real estates owned by the Directorate General of Foundations, the fused foundations and the foundations managed per procuration and were not paid by the publication date of the Law though they became due by 31.08.2020, the paragraph 10 of the article 4 prescribes that the collection of the accessory receivables such as late fee, interest pertaining to these receivables shall be waived provided that the relevant application is submitted by the end of the second month following the publication date of the Law and that the principals of these rents are entirely paid along with the legal expenses pertaining to the relevant actions and enforcement proceedings within three months following the publication date of the Law. In case the applicant wishes to pay, in installments, the receivables included in the scope of the said paragraph, it is possible to split these receivables into installments in equal portions and within maximum twelve months, to be paid along with their legal interests. In this case, the legal expenses pertaining to actions and enforcement proceedings shall be collected along with the first installment amount. In order to benefit from the provisions of the said paragraph, it is necessary that a relevant action has not been brought and that the action has been waived if there is such action brought.

As regards the Turkish Standards Institute’s receivables from real and legal persons which receivables are pursued and about which enforcement proceedings were initiated by the publication date of the Law and which are included in the scope of these persons’ service fields, for the amount to be calculated by taking the D-PPI monthly rates of change by the publication date of the Law instead of all the principals of these receivables and the accessory receivables calculated for these receivables, the collection of the accessory receivables such as late fee, default interest, interest calculated for these debts shall be waived, provided that the relevant application is submitted to the Turkish Standards Institutes’ departments in charge of pursuing and collection by the end of the second month following the publication date of the Law and that the first installment of the payable amount is entirely paid in the way and within the period specified by the Law and starting from the third month following the publication date of the Law. It is necessary for the obligors, who wish to benefit from the paragraph 12 of the article 4 contained in the Law, to fulfill the conditions specified by the paragraph, not to bring a relevant action, to waive of the action if there is such action brought and not to apply for legal remedies.  

Furthermore, according to the paragraph 16 of the article 4, as regards the administrative fines which are included in the scope of the Law and pertain to the determinations carried out prior to 31.08.2020 and became final until the date of the application referred to in the subparagraph (a) of the paragraph 1 contained in the article 3 from the publication date of the Law and were applied for until that date and are pursued by the Social Security Institution, in case of payment, in accordance with the provisions of the article 3, of the amount to be calculated for the 50% portion at the monthly rate of 0.35% for the period elapsed until the application date from the expiration dates of the payment periods and 50% of the administrative fine principals, the collection of all the accessory receivables applied to these administrative fines and the remaining 50% of the administrative fine principals shall be waived.

Conclusion

With the Law, the applicants are provided with the opportunity to restructure their tax debts, including income tax, corporate tax, VAT, MVT, SCT, all administrative fines, the General Directorate of Credit and Dormitories Agency debts and Treasury receivables; and the interest increases, delay penalties and administrative fines such as traffic fines, late fees, default interests and the receivables arising from the establishment of easements and from the leasing of the real estates that are left to the disposal of municipalities are also included into the scope of the restructuring. Furthermore, with the Law, the applicants are provided with the opportunity to restructure their tax debts and thereby, to pay their tax debts every two months and in maximum 18 installments.

The full text of the Law is accessible at:  

https://www.resmigazete.gov.tr/eskiler/2020/11/20201117-1.htm