VERGİSEL AÇIDAN BİNEK VE TİCARİ OTOMOBİLLER

VERGİSEL AÇIDAN BİNEK VE TİCARİ OTOMOBİLLER

Bu yazımızda ticaret şirketleri ve işletmelerin sahip olduğu ticari ve binek otomobillerden alınan ÖTV, (Özel Tüketim Vergisi) KDV,  (Katma Değer Vergisi) ve MTV’nin  (Motorlu Taşıt Vergisi) durumu, satışlarındaki KDV oranları ile amortisman mevzuu değerlendirilecektir.

  • BİNEK OTO VE TİCARİ OTO AYRIMI

Vergilendirme açısından bir aracı binek otomobil olarak tanımlayabilmek için o aracın 8 Seri No.lu Gümrük Genel Tebliği eki sınıflandırma kararının 87.03 tarife pozisyonunda yer alan şartları taşıması gerekmektedir.

Bu şartlar ;

  • Şoför ve ön yolcu bölümü ile yük ve insan taşınan arka bölüm arasında bir bariyer veya panel bulunmaması,
  • Şoför ve öndeki yolcunun arkasındaki kısımda emniyet kemeri veya montajı için tertibatın bulunması,
  • Şoför ve öndeki yolcunun arkasındaki kısımda koltuk ve emniyet ekipmanı montajı için sabit tertibat bulunması,
  • Şoför ve öndeki yolcunun arkasındaki kısımda aracın yolcu bölümlerinde yer alan konfor özellikleri ve iç döşemeleri (örn. yer kaplamaları, havalandırma, iç aydınlatma, küllükler) olması,
  • İki yan panel boyunca arka camları bulunması, (En arkada yük bölümü varsa bu bölümün sağ ve sol taraflarında cam bulunup bulunmamasının önemi yoktur)

Bu şartları taşıyan araçlar ruhsatına bakılmaksızın binek otomobil olarak kabul edilmektedir.

Yapılan bu açıklamalar göre; Doblo, Kango, Multix, Combo, Connect, Partner, Berlingo, Caddy, Vaneo, Fiorino, Bipper gibi kapalı kasalı, çift sıra koltuklu, şoför mahallinin arkasındaki bölümde de yan camları olan araçlar ile Starex, Traffic, Master, Vito, Viano, Transporter, Caravelle, Transit, Jumpy, Ducato, Boxer gibi kapalı kasalı, şoför mahallinin arkasında da koltuk bulunan, yanları camlı, city van veya camlı van olarak da adlandırılan, şoför dahil 9 kişiye kadar (8+1) insan taşıyan panelvan araçlar binek otomobil olarak değerlendirilecektir.

  • ÖTV AÇISINDAN DEĞERLENDİRME
  1. Binek Otomobiller Açısından

 ÖTV bir defaya mahsus olmak üzere araçların ilk alımında ödenmektedir.

VUK  269’ a göre,  taşıtlar gayrimenkuller gibi maliyet bedeli ile değerlenir. Yine aynı Kanunun gayrimenkullerin maliyet bedeli ile ilgili açıklamayı yapan 270. Maddesine göre: “………. Özel Tüketim Vergilerini maliyet bedelini ithal etmekte veya genel giderler arasında göstermekte  mükellefler serbesttirler.” denilmektedir.  Buna göre taşıtlara ait ÖTV’yi doğrudan gider yazmak ya da maliyete atmak mükellefin seçimine bırakılmıştır.

  1. Ticari Otomobiller Açısından

Ticari otomobiller açısından da yukarıda anlatılanların aynısı geçerlidir. Yani ÖTV’yi doğrudan gider yazmak ya da taşıtın maliyetine yüklemek mükellefin tercihine bağlıdır.

  • KDV AÇISINDAN DEĞERLENDİRME

 Satıştaki KDV Oranları Açısından İrdeleme

Ticaret şirketleri, işletmeler ve KDV mükellefi olmayan vatandaşlar tarafından ilk sıfır binek veya ticari araç alımlarında ödenen KDV %18’dir. Vatandaşların kullanılmış binek araç satışı KDV’nin konusuna girmediğinden doğal olarak bu satışlarda KDV hesaplanmayacaktır. Ticaret şirketleri ve işletmelerin kullanılmış ikinci el binek oto satışlarındaki hesaplanan KDV oranı %1,  ticari araç satışlarındaki KDV oranı ise %18 olacaktır.

Faaliyetleri kısmen veya tamamen binek otomobillerin kiralanması veya çeşitli şekillerde işletilmesi olanların satışları ise %18 KDV’ye tabidir.

  1. Alımdaki KDV’nin İndirilip İndirilemeyeceği Hususu
  • Binek Otomobiller Açısından

KDV Kanunu 30. Maddesi gereği binek otoların alış KDV’si indirim konusu yapılamamaktadır. (Faaliyetleri kısmen veya tamamen binek otomobillerin kiralanması veya çeşitli şekillerde işletilmesi olanlar hariç)  KDV Genel Uygulama Tebliği’nin I.C.2/1 Kısımına göre de : “ İndirim konusu yapılamayan bu vergi, Gelir ve Kurumlar Vergisi Kanunları çerçevesinde işin mahiyetine göre gider veya maliyet unsuru olarak dikkate alınabilir.” şeklindedir.  Dolayısıyla binek oto alış KDV’sinin doğrudan gider ya da maliyete atılma hususu da mükellefin seçimine bırakılmıştır.

  • Ticari Otomobiller Açısından

Ticari otomobiller açısından ise yüklenilen KDV, Katma Değer Vergisi Kanunu’nun 29. Maddesi çerçevesinde genel esaslara göre indirim konusu yapılabilecektir.

  • MTV AÇISINDAN DEĞERLENDİRME
  1. Binek Otomobiller Açısından

197 Sayılı Motorlu Taşıtlar Vergisi Kanunu’nun 14. maddesinde, ticari maksatla kullanılan uçak ve helikopter ile taşıt kiralama faaliyeti ile uğraşan işletmelerin bu amaçla kiraya verdikleri taşıtlar hariç olmak üzere, bu kanunun I, ve IV sayılı tarifelerinde yer alan taşıtlardan alınan (örneğin; otomobil, motosiklet, uçak, helikopter vb.) motorlu taşıtlar vergisi ve cezalar ile gecikme zamları, gelir ve kurumlar vergileri matrahının tespitinde gider olarak kabul edilemeyeceği hüküm altına alınmıştır.

Dolayısıyla, sadece taşıt kiralama faaliyeti ile uğraşan işletmelerin bu amaçla kiraya verdikleri binek otomobillere ait MTV’nin gider olarak dikkate alınabilecek, bunun dışındaki binek oto MTV’leri, kanunen kabul edilmeyen gider olarak dikkate alınacaktır.

  1. Ticari Otomobiller Açısından

Gelir ve Kurumlar Vergisi Kanunu’nda ticari araçların gider yazılmasını engelleyecek bir düzenleme olmadığından aktife kayıtlı ticari araçların MTV’leri gider olarak dikkate alınabilecektir.

  • AMORTİSMANLAR BAKIMINDAN DEĞERLENDİRME
  1. Binek Otomobiller Açısından

VUK (Vergi Usul Kanunu) nun 320. maddesi gereği, faaliyetleri kısmen veya tamamen binek otomobillerinin kiralanması veya çeşitli şekillerde işletilmesi olanların bu amaçla kullandıkları binek otomobilleri hariç olmak üzere, işletmelere ait binek otomobillerinin amortismanı kıst olarak hesaplanarak giderleştirilir.

  1. Ticari Otomobiller Açısından

Ticari otomobiller açısından amortismanlarda herhangi bir sınırlama olmadığından kıst amortisman olmaksızın hesaplama yapılabilecektir.

Bugünkü yazımızda binek ve ticari otomobillerin vergi kanunları açısından tüm yönleriyle ele alınması suretiyle, tereddüt edilen hususlarla ilgili açıklama yapılmaya çalışılmıştır.

 

Mesut ZURNACI

Yeminli Mali Müşavir

mesut.zurnaci@mzdenetim.com

 

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