Turkish Antitrust

Foreword Turkish Antitrust: An overview of national case law

This Special Issue aims to provide detailed insight into the contemporary approaches adopted by the Turkish Competition Board (“Board”), the decisional body of the Turkish Competition Authority (“Authority”) regarding anticompetitive agreements, unilateral conduct and mergers. The approaches adopted by the Board in its recent precedent are heavily influenced by global trends such as the close scrutiny over digital players as well as increasing attention towards competition law issues concerning labour markets. The substantive analysis regarding the anticompetitive agreements, unilateral conduct, and mergers has been shaped by Law No. 4054 on the Protection of Competition (“Law No. 4054”) as well as the secondary legislation. Further to Law No. 4054, there are several mechanisms for the Authority to focus on and to streamline certain of its processes, such as the use of the de minimis principle in its cases, “significant impediment of effective competition” (“SIEC”) test for merger control, behavioural and structural remedies for anti-competitive conducts, and procedural tools including leniency, commitment and settlement mechanisms. The articles within this Special Issue aim to reveal and explain the evolving efforts of the Board in establishing its case law in light of the amendments to the main and secondary legislation by way of also following global trends, as well as taking advantage of the well-established practices under the EU competition law regime in recent years, on various fronts.

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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)

Anticompetitive practices

The Turkish Competition Authority approves a household appliances manufacturer’s commitment package regarding online sales restrictions in a split decision (Arçelik)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Havard Law School (Cambridge, MA)
I. Introduction The Competition Board (“Board”) launched a full-fledged investigation against Arçelik Pazarlama AŞ (“Arçelik”), BSH Ev Aletleri San. ve Tic. AŞ (“BSH”), Gürses Kurumsal Tedarik ve Elektronik Tic. Paz. AŞ (“Gürses Kurumsal”), LG Electronics Tic. AŞ (“LG”), Samsung Electronics (...)

The Turkish Competition Authority concludes an investigation of restrictive practices and price fixing in the sports equipment sector with settlement and fine (Olka / Marlin)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Günay & Erdoğan Attorneys at Law (Ankara)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Introduction In June 2022, the Turkish Competition Board delivered its final judgment and announced that the investigation against Olka Spor Malzemeleri Ticaret AŞ (Olka) and Marlin Spor Malzemeleri Ticaret AŞ (Marlin), two undertakings active in the sports equipment sector, had ended with a (...)

The Turkish Administrative Court Ankara annuls the Competition Authority’s decision to impose an administrative monetary fine on a chemical supplier stating that the standard of proof has not been met (Hicri Ercili)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Havard Law School (Cambridge, MA)
The Ankara 9th Administrative Court (“Administrative Court”) annulled the decision of the Turkish Competition Board (“Board”) where an administrative fine of TL 11,214,051.26 was imposed on Hicri Ercili Deniz Nakliyat Kimyevi Maddeler San. ve Tic. Ltd. Şti.) (“Hicri Ercili”), a supplier of the (...)

The Turkish Competition Authority imposes administrative monetary fines on two companies for customer allocation following a leniency application, despite two dissenting opinions underlining the necessity for an effects-based analysis (Transorient / Tunaset)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The Turkish Competition Board (“Board”) imposed administrative monetary fines against Transorient Uluslararası Taşımacılık ve Ticaret A.Ş. (“Transorient”) and Tunaset Biofarma Lojistik Hizmetleri A.Ş. (“Tunaset”) for engaging in anticompetitive customer allocation agreements, while Biopharma (...)

The Turkish Competition Authority imposes a €173.8M fine on retail grocery chains and suppliers for resale price maintenance (Savola / A101 / Carrefour / Migros...)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
(1) Introduction On January 19, 2022, Turkish Competition Authority (“Authority”) has published a highly anticipated decision of the Competition Board (“Board”) regarding the investigation against retail grocery chains and suppliers of such chains, active in the fields of retail food and (...)

The Turkish Competition Authority rejects an individual exemption application between two online retailers which agreed not to bid for the keywords relevant to their rival’s brand (Modanisa / Sefamerve)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The Turkish Competition Authority Evaluates a Request from Modanisa for an Individual Exemption or Negative Clearance for the Settlement Agreement Regarding Restricting on Branded Keyword Bidding* This case summary includes an analysis of the Turkish Competition Board’s (“Board”) (...)

The Turkish Competition Authority issues a settlement decision following investigations on a home appliances manufacturer for resale price maintenance (Arnica Pazarlama)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Background On September 29, 2020, a complaint was brought to the Turkish Competition Authority’s (“Authority”) attention, where it was alleged that Arnica Pazarlama A.Ş.’s (“Arnica”) sales representative had called the complainant (who was one of Arnica`s authorized sellers, engaged in the (...)

The Turkish Competition Authority fines a manufacturer of small household appliances and its distributor for resale price maintenance and restrictive practices (Groupe SEB / İlk Adım)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Introduction Article 4 of Law No. 4054 on the Protection of Competition prohibits the fixing of: the purchase or sale price of goods or services; elements such as cost and profit that form price; and any other terms of purchase or sale. On 24 August 2021, the Competition Authority (...)

The Turkish Supreme Court annuls the Competition Authority’s decision to impose a fine on a manufacturer of personal and home care products for resale price maintenance and clarifies that RPM cases require an element of "coercion" or "incentive" (Henkel)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
This case summary includes an analysis of the 13th Chamber of the Council of State’s reversal (E. 2021/969, K. 2021/2654, 06.07.2021) of Ankara Regional Administrative Court’s judgment (E. 2020/394, K. 2020/2451, 23.12.2020). Ankara Regional Administrative Court upheld the Turkish Competition (...)

The Turkish Competition Authority grants an individual exemption for five years to a “frequent flyer cooperation agreement” between a national airline and a bank (Turkish Airlines / Kuveyt Turk)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Günay & Erdoğan Attorneys at Law (Ankara)
This case summary includes an analysis of the Turkish Competition Board’s (“Board”) Turkish Airlines and Kuveyt Turk exemption decision in which the Board determined that the "THY Frequent Flyer Program Miles&Smiles Credit Card Cooperation Agreement" (“Agreement”) cannot be issued a (...)

The Turkish Competition Authority lunches an investigation against 32 companies for gentlemen’s agreements across the labour market (Yemek Sepeti / Zomato / Commencis...)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
On April 20, 2021, the Turkish Competition Authority (“Authority”) announced on its website that the Turkish Competition Board (“Board”) had launched a full-fledged investigation against thirty-two undertakings for gentlemen’s agreements in labor markets across Turkey, in order to determine (...)

The Turkish Competition Authority imposes an administrative monetary fine on a major paint supplier for resale price maintenance and exclusive distribution (DYO)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
This case summary aims to shed light on the Turkish Competition Board’s (“Board”) DYO Decision, whereby the Board imposed an administrative fine of TL 21,036,866.58 to DYO Boya Fabrikaları Sanayi ve Ticaret A.Ş. (“DYO”), a major paint supplier in Turkey, on the ground that DYO has violated (...)

The Turkish Competition Authority issues a decision on the analysis of alleged price coordination of undertakings in the welding sector underscoring the importance of economic analysis when investigating infringement complaints (Magmaweld / Oerlikon / Askaynak / Gedik)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Günay & Erdoğan Attorneys at Law (Ankara)
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Arçelik Global (Istanbul)
I Introduction On July 29, 2019 a complaint was brought to the Turkish Competition Authority’s (“Authority”) attention, which alleged that certain undertakings operating in the welding sector acted together and subsequently violated the Law No. 4054 on the Protection of Competition (“Law (...)

The Turkish Competition Authority imposes fines on two pharmaceutical companies for engaging in concerted practices to expand the use of Lucentis as opposed to Altuzan in treating eye diseases (Roche / Novartis)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The Turkish Competition Board (“Board”) decided that Novartis and Roche violated Article 4 of the Law No. 4054 on the Protection of Competition (“Law No. 4054”) by way of engaging in concerted practice to expand the use of Lucentis as opposed to Altuzan, both of which are the drugs used for (...)

Unilateral Practices

The Turkish Competition Authority fines a maker of small home appliances for resale price maintenance and imposes restrictions on online sales (Arnica Pazarlama)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Arçelik Global (Istanbul)
Introduction On 4 March 2021, the Turkish Competition Board initiated an investigation to establish whether Arnica Pazarlama AŞ (Arnica), a supplier of small home appliances, had violated article 4 of Law No. 4054 on the Protection of Competition (Law No. 4054) through: resale price (...)

The Turkish Competition Authority imposes interim measures against the exclusive broadcaster of the Turkish Super League football games (Krea İçerik Hizmetleri)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Introduction The Turkish Competition Board (“Board”) initiated in September 2022 a preliminary investigation against Krea İçerik Hizmetleri ve Prodüksiyon A.Ş. (“Krea”), a company holding exclusive broadcasting rights of the Turkish Super League and Turkish First Division League football (...)

The Ankara 8th Regional Administrative Court reverses the 13th Administrative Court’s decision that annulled the Turkish Competition Authority’s decision on an exemption application of an FMCG company for its selective distribution agreement (Johnson & Johnson)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
This article aims to provide a case analysis of the Ankara 8th Regional Administrative Court’s (“Regional Court”) judgement annulling Ankara 13th Administrative Court’s (“Administrative Court”) judgement that annulled the Turkish Competition Board’s (“Board”) Johnson&Johnson Sıhhi Malzeme (...)

The Turkish Competition Authority emphasises the importance of not turning recommended and maximum resale prices into resale price maintenance practices (Monsanto)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Arçelik Global (Istanbul)
Introduction On 30 July 2021, Monsanto Gıda ve Tarım Tic Ltd Şti (Monsanto), a manufacturer of agricultural and vegetable seeds, herbicides and digital agricultural products, applied to the Turkish Competition Authority for the grant of negative clearance or exemption in favour of the (...)

The Turkish Competition Authority investigates an online marketplace for vehicles and real estate over an alleged abuse of dominance (Sahibiden)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The Turkish Competition Authority has continued its investigations into alleged anti-competitive practices in digital markets. This time, the Competition Board (the Authority’s decision-making body) has launched a fully fledged investigation against Sahibinden Bilgi Teknolojileri Paz ve Tic (...)

The Turkish Competition Authority fines an online second-hand books company for abuse of dominance (Nadirkitap)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Freedom Now (Washington)
This article has been nominated for the 2023 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. I. Introduction The Turkish Competition Authority (“ Authority ”) has published its Nadirkitap decision in which it evaluated the allegation as to whether (...)

The Turkish Competition Authority rejects an allegation that an online food delivery company has abused its dominant position through most favoured customer practices and de facto exclusivity (Yemek Sepeti)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
This case summary aims to offer insight on the Turkish Competition Board’s (“Board”) Yemek Sepeti Decision (“Decision”), whereby the Board examined the allegation that Yemek Sepeti Elektronik İletişim Perakende Gıda Lojistik A.Ş. (“Yemek Sepeti”) had abused its dominant position, violating (...)

The Turkish Competition Authority accepts for the first time in the preliminary investigation stage commitments proposed by a glass manufacturing company to remedy competition concerns relating to an abuse of dominance in the glass production market (Şişecam)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The Turkish Competition Board (“Board”) decided that Şişecam, through its subsidiary Çevre Sistemleri, has abused its dominant position in the market for glass manufacturing, by way of excluding its competitors in the upstream market for recycled glass, utilized its buyer power to narrow the (...)

The Turkish Competition Authority issues interim measures against a leading marketplace platform for its use of algorithms and third-party data to benefit its own offerings (Trendyol)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
This case summary includes an analysis of the Turkish Competition Board’s (“Board”) Trendyol Interim Measure decision in which the Board, upon the findings of its preliminary investigation, determined that DSM Grup Danışmanlık İletişim ve Satış Ticaret A.Ş.’s (“Trendyol”) use of algorithms and (...)

The Turkish Competition Authority accepts a leading beverage company’s commitments to remedy competition concerns over its abuse of dominance in the carbonated drinks, cola drinks and aromatic carbonated drinks markets (Coca Cola)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The changes to the Law No. 4054 on Protection of Competition (“Law No. 4045”) introducing the new commitment and settlement mechanisms, entered into force on 24 June 2020 with the Amendment Law, aiming to achieve efficiency gains and allow the competition investigations to close at an earlier (...)

The Turkish Competition Authority closes an investigation into alleged abuse of dominance by withholding access to codes and activation tools required for the maintenance and repair of medical imaging devices (Philips Turkey)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The Turkish Competition Board (the “Board”) launched a full-fledged investigation against Türk Philips A.Ş (“Philips Turkey”) into allegations of abuse of dominance through denying or delaying access to codes and activation tools required for the maintenance and repair of medical imaging (...)

The Turkish Competition Authority finds manufacturers of medical imaging and diagnostic devices not liable for abuse of dominance in relation to the provision of access codes and activation tools for the maintenance of medical imaging devices (Philips Turkey)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
This case summary includes an analysis of the Turkish Competition Board’s (“Board”) Philips decision (26.08.2021, 21-40/589-286) in which the Board determined that Türk Philips Ticaret A.Ş. (“Philips Turkey”) did not abuse its dominant position through denying or delaying access to codes and (...)

The Turkish Competition Authority closes an investigation against an alcohol manufacturer for alleged abuse of dominance in accordance with the ne bis in idem principle (Mey İçki)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
In September 2011, the Turkish Competition Authority (the “Authority”) initiated a preliminary investigation against Mey İçki, a subsidiary of Diageo plc. in order to decide whether it violated Article 6 of Law No. 4054 on Protection of Competition (“Law No.4054”) in the Turkish market for (...)

The Turkish Competition Authority announces its decision to launch a fully-fledged investigation against two Big Tech companies (Facebook / WhatsApp)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Introduction The Competition Board recently announced its decision to launch a fully fledged investigation, ex officio, against Facebook Inc, Facebook Ireland Ltd, WhatsApp Inc and WhatsApp LLC (together, ’Facebook’) in order to assess whether they had violated Article 6 of Law 4054 on the (...)

Mergers

The Turkish Competition Authority publishes a new decision regarding the local threshold exception for acquisitions in the software sector (Providence / Airties)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Introduction On 2 June 2022, the Turkish Competition Board unconditionally approved the indirect acquisition of sole control over Airties Kablosuz İletişim San ve Dış Tic AŞ (Airties) by Providence Managing Member LLC’s (Providence’s) wholly-owned indirect subsidiary, P8 Holding 2 Sàrl (P8 (...)

The Turkish Competition Authority sees a new merger control regime enter into force, amending notification thresholds and the scope of applicable sectors
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
(1) Introduction On March 4, 2022 the Turkish Competition Authority (“Authority”) published the Communiqué No. 2022/2 on the Amendment of Communiqué No. 2010/4 on the Mergers and Acquisitions Subject to the Approval of the Competition Board (the “Amendment Communiqué”). The Amendment (...)

The Turkish Competition Authority gears up to raise the jurisdictional turnover thresholds and to introduce specific rules to catch killer acquisitions
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Communiqué No. 2022/2 on the Amendment of Communiqué No. 2010/4 (“ Communiqué No. 2010/4 ”) on the Mergers and Acquisitions Subject to the Approval of the Competition Board (“ Amendment Communiqué ”) has been published on the Official Gazette on March 4, 2022 and will enter into force on May (...)

The Turkish Competition Authority clears the acquisition for sole control of a porcelain producer by an American private equity firm following divestment commitments (Ferro / American Securities)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
The Turkish Competition Board (“Board”) conditionally approved the acquisition of sole control over Ferro Corporation (“Ferro”) by American Securities LLC (“American Securities”) through its solely controlled affiliate ASP Prince Holdings Inc. (“Prince”). The Board determined that the (...)

The Turkish Competition Authority conditionally clears a merger of two online ticket-selling platforms active in the sale of bus and flight excursions (Biletal / Obilet)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Erdem & Erdem (Istanbul)
The Turkish Competition Authority (the "Authority") published its Obilet/Biletal decision where it conditionally approved the acquisition of Biletal İç ve Dış Ticaret A.Ş.’s (“Biletal”) sole control by Obilet Bilişim Sistemleri A.Ş. (“Obilet”) and decided that the proposed transaction would (...)

The Turkish Competition Authority unconditionally clears the acquisition of a machine manufacturer’s process and motion control business by its parent company through a reverse Morris trust (Regal / Rexnord)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Günay & Erdoğan Attorneys at Law (Ankara)
On 15 April 2021, the Competition Board (the Board) unconditionally approved Regal Beloit Corporation’s acquisition of sole control over Rexnord Corporation’s process and motion control (PMC) business segment. Facts The transaction concerns an acquisition carried through reverse Morris (...)

Procedures

The Turkish Competition Authority fines a leading electric scooter company for providing false and misleading information (Martı)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Havard Law School (Cambridge, MA)
Do you think the information requested from the Competition Authority is not available in your company records? Check It Twice! The Competition Board Fines Martı İleri Teknoloji AŞ for Providing False/Misleading Information* The Turkish Competition Board (“ Board ") imposed an administrative (...)

The Ankara 2nd Administrative Court stays the imposition of a substantial fine for obstructing a dawn raid by deleting WhatsApp messages because the messages remained retrievable through other employees and were not relevant to the investigation (Sahibinden)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Arçelik Global (Istanbul)
This case summary includes an analysis of the Ankara 2nd Administrative Court’s (“the Court of First Instance”) Sahibinden SoE decision (E. 2022/254, 15.04.2022) in which the Court of First Instance stays of execution of the Board’s decision where the Board imposed an administrative monetary (...)

The Turkish Competition Authority concludes an investigation into the small household appliances sector with the first settlement decision under the newly introduced settlement procedure (Philips / Dünya Dış)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
After an investigation process of 8 months, the Turkish Competition Board (“Board”) announced on August 9, 2021 on its website that it has concluded the investigation with a settlement decision which constitutes the first example of the newly introduced settlement procedure by the Turkish (...)

The Turkish Competition Authority introduces a settlement mechanism under national competition law
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
In an effort to take one step further in harmonizing the Turkish Competition Law with the EU legislation, the Turkish Competition Authority (“Authority”) has recently introduced the settlement mechanism under Article 43 of the Law No. 4054 on the Protection of Competition (“Law No. 4054”) and (...)

The Turkish High State Court upholds the Competition Authority’s non-fining decision by implementing the non bis in idem principle (Mey İçki / Antalya Alkollü / Efe Alkollü)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Trendyol (Ankara)
Introduction In April 2016, the Turkish Competition Board (the “Board”) launched an investigation against Mey İçki San. ve Tic. A.Ş. (“Mey İçki”), a subsidiary of Diageo plc. The investigation aimed to explore the validity of the allegations regarding Mey İçki`s abuse of dominance in the (...)

Regulatory

The Turkish Competition Authority issues the Regulation on Settlement Procedure for Investigations on Anticompetitive Agreements, Concerted Practices, Decisions and Abuse of Dominant Position
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
Introduction On July 15, 2021, the Turkish Competition Authority (“Authority”) issued the Regulation on Settlement Procedure for Investigations on Anticompetitive Agreements, Concerted Practices, Decisions and Abuse of Dominant Position (“Settlement Regulation”), which was also published in (...)