Vergi ziyaı cezası

When tax goes unassessed because conditions for a benefit were never met, Türkiye treats it as vergi ziyaı — lost tax. The consequence stack is the original tax, a tax-loss penalty (typically equal to the tax itself), and late-payment interest. Communiqué No. 333's Example 12 applies exactly this track to a cancelled İstisna Belgesi: the certificate was granted, a later audit found an unregistered business in the lookback years, and the exemption unwound retroactively with penalty and interest across every affected year.