Both the Court of Appeal and the Federal Court have upheld this legal situation through their multiple court decisions. Indeed, both the Court of Appeal in its decision of 16.06.2010 and the number E. 2010/1-275; K. 2010/327[ii] and the Swiss Federal Court[iii] find that, if there is a simulated transaction, the simulated agreement is not valid. Two types of simulated transactions are accepted according to Turkish legal doctrine; “Absolute simulation” and “relative simulation”. Absolute simulation means an agreement between the parties to deceive third parties, to obtain any advantage, as if there were a real and true underlying agreement between the parties. As far as relative simulation is concerned, it is an agreement between the parties for the purpose of concealing the actual (underlying) agreement. The Supreme Court itself recognizes the validity and effectiveness of the disguised, not simulated operation.