There’s a point business owners frequently confuse: the money that lands in the bank account is not the same as the business’s real profit. The VAT collected on a sale isn’t the business’s own earnings — it’s essentially being held in trust for the state. In this article, we walk through how a business’s real net profit is calculated, step by step, using an example.

A Worked Example

Let’s assume a business purchases goods for TRY 300,000 plus 20% VAT, and sells them with a 30% profit margin.

1. Purchase Stage

• Cost of Goods: TRY 300,000
• VAT (20%): TRY 60,000
• Total Payment: TRY 360,000

Important: This TRY 60,000 in VAT is not a cost to the business. It’s recorded as “deductible VAT” and later offset against the VAT collected on sales.

2. Sale Stage

• Sale Price (excl. VAT): TRY 390,000 (a 30% margin on TRY 300,000)
• VAT Calculated (20%): TRY 78,000
• Total Amount Collected: TRY 468,000

3. Trading Profit

Sale Price (excl. VAT) TRY 390,000 − Cost of Goods TRY 300,000 = Gross Trading Profit: TRY 90,000

4. Taxes

• Corporate Tax (25% standard rate): TRY 22,500
• VAT Collected: TRY 78,000
• Deductible VAT: TRY 60,000
• VAT Payable to the State: TRY 18,000

Important: VAT is not the business’s earnings. The business simply offsets the VAT paid on purchases against the VAT collected on sales, and remits the difference to the state.

5. Net Profit After Tax

Gross Trading Profit TRY 90,000 − Corporate Tax TRY 22,500 = Sample Net Profit: TRY 67,500

What’s Not Included in This Example

The calculation above has been simplified to explain the concept clearly. A real business has many additional items affecting net profit that aren’t included in this example:

• Personnel expenses (salaries, social security premiums, severance/notice pay provisions)
• Operating expenses such as rent, electricity, water, and natural gas
• Accounting and CPA fees
• Financing costs (loan interest, bank charges)
• Withholding tax deductions
• Depreciation expenses

All of these items make up a business’s operating expenses and can reduce real net profit well below the amount calculated in this example. For this reason, every business’s actual net profit needs to be calculated carefully and individually, based on its own income and expense structure.

Why It Matters

Mistaking the bank balance for profit is one of the most common errors business owners make. Part of the VAT collected goes to the state, corporate tax is owed on the profit, and operating expenses must still be deducted — what’s left is often less than the account holder expected. Making pricing, investment, or spending decisions without knowing your real profit can negatively affect your business’s cash flow.

At Mete CPA & Auditing, we support you from accurately calculating your business’s real profitability to pricing and tax planning. Contact us to review your situation.

Under General Communiqué No. 573 on the Tax Procedure Law, published in the Official Gazette dated November 12, 2024, the legal groundwork was laid for issuing the “expense voucher” (gider pusulası) electronically, with the Turkish Revenue Administration (GİB) authorized to implement it. Joining e-invoice, e-archive invoice, and e-waybill in Turkey’s e-transformation family, this new document became mandatory for certain taxpayer groups as of January 1, 2026. In this article, we summarize what the e-Expense Voucher is, who must use it, and how the issuance process works.

What Is an Expense Voucher?

The expense voucher (gider pusulası) is a document defined under Article 234 of the Tax Procedure Law. For purchases of goods or services from individuals who are not registered taxpayers, since the seller cannot issue an invoice, this document is issued by the purchasing business instead. Common examples include purchases of second-hand goods and vehicles, scrap deliveries, returns from final consumers, and purchases from individuals benefiting from the tradesman exemption.

Who Is Required to Use It?

Importantly, the e-Expense Voucher is not a blanket requirement for all taxpayers. The obligation arises through two separate paths:

• Certain retail businesses: businesses operating under NACE code 47 (retail trade) that are enrolled in the e-invoice system and meet at least two of the financial criteria set as of the end of the 2024 fiscal year (for example, sales or gross business revenue exceeding TRY 110 million) are required to issue e-Expense Vouchers as of January 1, 2026.
• Taxpayers found to be risky or to have a low compliance level: regardless of revenue or sector, any taxpayer that GİB’s risk analysis identifies as “risky” or having a “low level of tax compliance” may receive a written notification. Businesses receiving this notification must transition within at least 3 months of the notification date.

This second path operates on the same logic as the KURGAN risk analysis system we covered earlier — the tax administration can direct taxpayers it identifies as risky in their documentation practices straight into the electronic document regime.

All taxpayers outside these two categories may voluntarily switch to the e-Expense Voucher system at any time they wish to digitalize their processes, without waiting for any obligation.

Issuance Deadline and Method

The e-Expense Voucher must be issued within 7 days of the transaction date. Signing requires a financial seal for legal entities, or an e-signature for individuals. Issuance can be done via the GİB portal or through licensed integrators; for businesses with high transaction volumes, an integrator solution largely automates the process.

Required Information on the Document

An e-Expense Voucher must include the following information in full:

• Document date, time, and document number,
• The issuing business’s name, address, tax office, and tax ID number,
• The counterparty’s full name, residential address, and national ID number,
• The type, quantity, and value of the goods or services,
• The withholding tax rate and amount, VAT if applicable, and the total amount.

Missing any of these fields can render the document invalid.

Recommendations for Taxpayers

• If you operate in the retail sector, check whether you meet the financial criteria based on your 2024 fiscal year figures.
• If you have received a written notification from GİB, begin preparations immediately so you don’t miss the 3-month transition window.
• Even if you’re not within scope, consider a voluntary transition to reduce the cost of paper-based processes.
• Make sure your financial seal or e-signature is current and valid.
• Review your first few issuances with your CPA to make sure all required fields are filled in correctly.

At Mete CPA & Auditing, we support you from determining your e-Expense Voucher obligation to ensuring a smooth application and issuance process. Contact us to review your situation.

Under Law No. 7582, published in the Official Gazette dated June 4, 2026 (No. 33270), Repeated Article 20/D was added to the Income Tax Law, granting individuals who settle in Turkey a 20-year income tax exemption on their foreign-sourced income. Viewed alongside the Asset Peace regulation we covered earlier, this exemption presents a significant opportunity for expatriates planning to settle in Turkey and individuals earning income abroad. In this article, we summarize who qualifies, the scope of the exemption, and the points to watch for.

Who Qualifies for the Exemption?

To benefit from the Repeated Article 20/D exemption, three conditions must be met together:

• Deemed resident of Turkey: under Article 4 of the Income Tax Law, a person is deemed resident in Turkey if their domicile is in Turkey, or if they reside continuously in Turkey for more than 6 months within a calendar year.
• No domicile in Turkey for the preceding 3 calendar years: the individual must not have had a domicile in Turkey in the three calendar years prior to settling.
• No tax liability in Turkey for the preceding 3 calendar years: during the same period, the individual must not have had continuous tax liability arising from commercial, agricultural, or self-employment income.

For example, an individual settling in Turkey in 2026 must have had no domicile and no continuous tax liability in Turkey during 2023, 2024, and 2025 to qualify for the exemption.

What Does the Exemption Cover?

For individuals meeting the conditions, all types of income and earnings generated outside Turkey are exempt from income tax for 20 years from the date of settlement. Key points:

• The exemption is granted only to individuals; companies (corporate entities) cannot benefit from this regulation.
• There is no requirement to transfer foreign earnings to Turkey; the transfer of funds does not affect eligibility.
• No tax return needs to be filed in Turkey for foreign income covered by the exemption.

What Do You Give Up in Exchange for Not Filing?

The benefit of not filing a return comes with a trade-off: expenses and costs related to the exempt income cannot be deducted against other income, and taxes paid abroad on this income cannot be credited in Turkey. For this reason, whether the exemption is genuinely advantageous should be assessed individually, based on the person’s income structure and their tax burden abroad.

Advantage in Inheritance and Gift Tax

In the event of death during the exemption period, a reduced 1% rate of inheritance and gift tax may apply to assets transferred by inheritance — an additional benefit offered by the regulation.

When Does It Take Effect?

The regulation entered into force on its publication date, applying to individuals deemed resident in Turkey from January 1, 2026 onward; the implementation procedures were set out in General Communiqué No. 333 on Income Tax, published in the Official Gazette dated July 4, 2026 (No. 33300). Repeated Article 20/D has no expiration date — as long as the regulation remains in force, individuals who settle in Turkey in later years can also benefit from their own 20-year exemption period, starting from their individual settlement date, provided they meet the conditions.

A Risk to Be Aware Of

If it is later determined that the eligibility conditions were breached, this creates a risk of a penalized tax assessment. For this reason, it is important to document the settlement date and the individual’s domicile and tax liability status for the preceding three years.

Who Should Pay Attention?

• Turkish citizens who have lived abroad for an extended period and are planning to permanently return to Turkey,
• Foreign nationals earning income abroad who are considering settling in Turkey,
• Remote workers and digital nomads with foreign-sourced investment income or self-employment earnings.

At Mete CPA & Auditing, we support you from planning your settlement process in Turkey to documenting your eligibility for the 20-year exemption. Contact us to review your situation.

Company formation in Turkey may look complete once the Trade Registry issues the registration, but that’s really just the beginning. Fifteen follow-up steps must be completed afterward — some of them time-sensitive and subject to administrative fines. The minimum capital increase requirement we covered earlier can also apply to this list for existing companies. In this article, we summarize the 15 steps that must be completed after incorporation and the deadlines to watch for.

Two Critical Steps With Deadlines and Penalties

Among the 15 steps, two stand out because missing their deadline directly triggers an administrative fine:

• E-Notification Application: must be filed with the relevant tax office within 15 days of incorporation.
• Ultimate Beneficial Owner Declaration Form: must be submitted electronically via the Digital Tax Office within 1 month of establishing tax liability. This declaration then becomes an annual obligation, due again by August 31 each year. An administrative fine applies for each declaration not filed on time.

15 Steps to Complete After Incorporation

1. Sign the TÜRMOB and GİB agreements — the accounting services agreement and the electronic tax return filing agency agreement.
2. Obtain a signature circular — granting authorization to relevant persons for financial transactions.
3. Obtain Digital Tax Office login credentials.
4. Generate the tax certificate (vergi levhası) — via the online tax office.
5. File the e-notification application — within 15 days of incorporation.
6. File the Ultimate Beneficial Owner Declaration Form — within 1 month of incorporation.
7. File the e-ledger application.
8. Apply for a financial seal (mali mühür) — a priority step, since e-invoice and e-ledger applications require it.
9. Declare stamp duty on the lease agreement and the TÜRMOB agreement.
10. Activate UETS (National Electronic Notification System).
11. Obtain a KEP (registered electronic mail) address (optional) — issued by the PTT Directorate.
12. File the SGK (Social Security) notification application.
13. File the e-invoice application (optional, together with the financial seal).
14. Obtain e-signatures for partners if the resolution book is kept electronically.
15. Open an SGK file and obtain login credentials (if the company will employ staff).

Why Does This Matter So Much?

Some of these steps are interdependent — for example, the e-invoice and e-ledger applications cannot be filed without the financial seal, so getting the sequence right avoids wasted time. Missing either of the two time-sensitive steps (e-notification, beneficial owner declaration) results directly in an administrative fine — and since the beneficial owner declaration is an annual recurring obligation, this deadline needs ongoing tracking, not just a one-time check.

Recommendations for New Company Owners

• As soon as incorporation is registered, add the time-sensitive steps (e-notification, beneficial owner declaration) to your calendar.
• Apply for the financial seal early, since your e-invoice and e-ledger processes depend on it.
• Consider completing optional steps (KEP, e-invoice) early too, in case they become mandatory for your business in the future.
• If you plan to hire staff, complete the SGK file setup before the employee’s start date.
• Turn the full list into a checklist with your CPA and track it step by step.

At Mete CPA & Auditing, we support newly established companies in completing all 15 steps fully and on time, and in tracking recurring statutory deadlines. Contact us to review your situation.

Under Presidential Decree No. 7887, published in the Official Gazette dated November 25, 2023 (No. 32380), the minimum share capital amounts for joint-stock companies (A.Ş.) and limited liability companies (Ltd. Şti.) in Turkey were significantly increased. Subsequently, Law No. 7511, published in the Official Gazette dated May 29, 2024 (No. 32560), granted existing companies a transition period to comply with these new amounts. In this article, we summarize the new minimum capital requirements, the deadline, and the consequences of failing to increase capital in time.

What Are the New Minimum Capital Amounts?

Under Presidential Decree No. 7887, the minimum capital amounts set out in Article 332 of Turkish Commercial Code No. 6102 were raised as follows:

• Joint-stock companies (A.Ş.): from TRY 50,000 to TRY 250,000
• Limited liability companies (Ltd. Şti.): from TRY 10,000 to TRY 50,000
• Non-public joint-stock companies operating under the registered capital system: initial capital raised to TRY 500,000

These new amounts became directly applicable to newly established companies as of January 1, 2024.

Transition Period for Existing Companies

Provisional Article 15, added to the Turkish Commercial Code under Article 17 of Law No. 7511, granted a transition period to companies established before January 1, 2024 whose capital falls below the new minimum amounts. Accordingly:

• Joint-stock companies with capital below TRY 250,000 and limited liability companies with capital below TRY 50,000 must raise their capital to these amounts by December 31, 2026.
• Non-public joint-stock companies under the registered capital system with issued capital of at least TRY 250,000 must raise both their initial and issued capital to TRY 500,000 by the same date.

To facilitate this process, the legislator provided that general assembly meetings held to increase capital to the minimum amounts will not require a quorum, resolutions will be adopted by a majority of votes present, and no privileged voting rights may be exercised against such resolutions.

What Happens If Capital Isn’t Increased in Time?

This carries a serious consequence that should not be overlooked:

• For joint-stock and limited liability companies: if capital is not raised to the minimum amount by December 31, 2026, the company is deemed dissolved — meaning it is legally considered to have ceased to exist, and liquidation proceedings begin.
• For non-public joint-stock companies under the registered capital system: if capital is not raised to TRY 500,000, the company is deemed to have exited the registered capital system.

Although the Ministry of Trade has been granted authority to extend this deadline by up to one year, twice, taxpayers should plan their process now rather than relying on the possibility of an extension.

Recommendations for Companies

• Check whether your company’s current issued/registered capital falls below the new minimum thresholds.
• Plan the required general assembly and registration process for the capital increase well in advance; don’t leave it until the final quarter of 2026.
• Work with your CPA to decide whether the increase will be in cash or in kind, the payment schedule, and its effects on your current ownership structure.
• If your company operates under the registered capital system, make sure both your initial and issued capital meet the TRY 500,000 threshold.

At Mete CPA & Auditing, we support you from determining your company’s capital increase obligation to fully managing the general assembly and registration process. Contact us to review your situation.

Under General Communiqué No. 49 on the Law of Independent Accountancy, Financial Advisory, and Sworn-in Financial Advisory, published in the Official Gazette dated December 30, 2025 (No. 33123), income and corporate taxpayers must now submit a certification report prepared by a Sworn-in Certified Public Accountant (YMM) in order to benefit from certain exemptions, deductions, and applications reported on their tax returns. In this article, we summarize the scope of this certification requirement, the monetary thresholds, and the consequences of failing to submit the report.

What Does the Certification Requirement Cover?

Importantly, this requirement is not a blanket obligation covering all exemptions and deductions on a tax return. It applies only to the specific exemptions, deductions, and applications listed in the table under the second paragraph of Article 4 of the Communiqué. The regulation applies from corporate tax returns for the 2025 fiscal year onward, directly affecting returns filed in 2026.

What Are the Monetary Thresholds?

The certification requirement is triggered by the following thresholds:

• Amounts exceeding TRY 500,000 for each individual exemption/deduction item shown on a separate line of the return,
• Amounts exceeding TRY 1,000,000 for the combined total of these items.

If either threshold is exceeded, a YMM certification report becomes mandatory for the relevant exemption/deduction. For income taxpayers, the requirement covers certain items shown on separate lines of the return; for corporate taxpayers, the scope is broader, covering 21 separate categories. Importantly, this regulation does not only apply to high-revenue “full certification” taxpayers — it also applies to businesses with lower revenue that report a significant exemption or deduction amount on their return.

Report Deadline and Submission Method

Certification reports must be submitted electronically through the Digital Tax Office within 2 months following the tax return filing deadline (3 months for real estate investment trust earnings). Taxpayers who already have a full certification agreement do not need to submit a separate report, provided the matters covered by the Communiqué are included in their full certification report; however, YMMs remain jointly and severally liable with the taxpayer for the accuracy of the certification.

What Happens If the Report Isn’t Submitted?

If the certification report is not submitted on time, the process works as follows:

• The taxpayer is given an additional grace period to submit the report.
• If the report is still not submitted by the end of this grace period, the taxpayer loses the right to benefit from the relevant exemption or deduction.
• A special irregularity penalty also applies (set at TRY 330,000 for 2025).

Recommendations for Taxpayers

• Check in advance whether the exemption and deduction items on your return exceed the TRY 500,000 / TRY 1,000,000 thresholds.
• If you do not have a full certification agreement and have an exemption/deduction exceeding the thresholds, remember that a standalone YMM certification report is required for that specific item.
• Start the certification process immediately after filing your tax return; don’t leave the 2-month (or 3-month, for REITs) window until the last day.
• Work with your CPA to confirm which of your exemptions/deductions fall under the table in Article 4 of the Communiqué — not every exemption or deduction is covered.

At Mete CPA & Auditing, we support you from determining whether the exemptions and deductions on your tax return fall under the certification requirement, to ensuring your YMM certification report is completed accurately and on time. Contact us to review your situation.

When a company holds cash in excess of its ordinary business needs, or lends money to its partners, one of the most common issues raised in tax audits is which interest rate should be used in the “adat” calculation — the notional interest calculation applied to such balances. Turkey’s Council of State (Danıştay) has established a clear line of precedent on this issue. In this article, we explain what the adat calculation is, which interest rate should be used according to the Council of State, and its tax consequences.

What Is the Adat Calculation?

“Adat” refers to the notional interest calculation applied to cash held in a company’s till in excess of its ordinary operating needs, or to funds lent to partners without charge. The tax administration closely monitors such situations, treating them as carrying a risk of disguised profit distribution when company resources are made available to partners or related parties free of charge. To eliminate this risk, taxpayers are expected to calculate notional interest on the amounts involved at a market rate and record it as income.

Which Interest Rate Should Be Used?

The order of priority for determining the applicable interest rate in an adat calculation is as follows:

• If an internal comparable exists: the interest rate applied to the company’s own bank loans should be used.
• If no internal comparable exists (external comparable): according to the Council of State’s well-established case law, the rediscount interest rate announced by the Central Bank of the Republic of Turkey (CBRT) should be used.

Why the Rediscount Rate, Not the Advance Rate?

In practice, the tax administration sometimes bases adat calculations during audits on the CBRT’s advance interest rate instead. However, the well-established approach adopted by the Council of State in numerous rulings finds this practice unlawful. According to the Council of State, the interest rate that should be applied in adat calculations relevant to determining the tax base is the rate applied to rediscount transactions; where a calculation is instead based on the advance interest rate, the portion exceeding the rediscount rate is considered unlawful. Since the rediscount and advance interest rates are set for different purposes, using one in place of the other is not accepted by the Council of State.

Current Rediscount and Advance Interest Rates

Rates set by the CBRT are updated periodically and take effect through communiqués published in the Official Gazette. As of the current period, the discount interest rate applied to rediscount transactions for bills with no more than 3 months remaining to maturity has been set at 9.75% annually, while the rate applied to advance transactions has been set at 10.75% annually. The gap between these two rates directly affects the direction and size of any tax base adjustment if the wrong rate is applied.

Tax Consequences of Adat Interest

Adat interest calculated at the correct rate gives rise to two separate tax obligations for the taxpayer:

• Corporate tax: the calculated adat interest is treated as income, included in the company’s taxable profit, and subject to corporate tax.
• VAT: since lending money to partners is treated as a financing service under the VAT Law, VAT must be calculated and declared on the adat interest amount.

Recommendations for Taxpayers

• Regularly monitor your till balance and amounts lent to partners; identify any excess over your ordinary cash needs.
• Check for an internal comparable first (your own bank loan interest rate, if any) when performing an adat calculation.
• If no internal comparable exists, base the calculation on the CBRT rediscount interest rate; avoid using the advance interest rate.
• If you face a tax assessment based on the advance interest rate during an audit, consider your right to object by citing the Council of State’s well-established case law.
• Review your adat interest calculations and related VAT/corporate tax filings together with your CPA.

At Mete CPA & Auditing, we support you throughout the entire process — from ensuring your adat calculations align with Council of State precedent, to preparing a solid defense in the event of a tax audit. Contact us to review your situation.

Properly closing the Customs Exit Declaration (Gümrük Çıkış Beyannamesi, “GÇB”) for export transactions is key to avoiding serious consequences such as tax penalties, loss of incentives, and delayed VAT refunds. In this article, we summarize the 7 key steps in the GÇB closing process and the risk areas to watch for.

What Is a GÇB and Why Must It Be Closed?

The Customs Exit Declaration (GÇB) is the official document confirming that goods have been exported from Turkey’s customs territory. However, filing the declaration alone is not enough — a series of follow-up steps, from bringing export proceeds into the country to filing the VAT refund, must be completed in full to close the file. A GÇB file left incomplete can create risks of tax audits, incentive clawback, or administrative fines under foreign exchange regulations.

7 Key Steps in the GÇB Closing Process

1. GÇB Information

Verify that the declaration number is correct, and that the HS code (Harmonized System / customs tariff classification), quantity, and amounts match the invoice exactly.

2. Repatriation of Export Proceeds

Confirm whether the export proceeds were brought into the country within the legal deadline, and whether an Export Proceeds Acceptance Certificate (İBKB) or Foreign Exchange Purchase Certificate (DAB) was issued.

3. Invoice Verification

The e-export invoice must match the GÇB exactly; the currency and amount must be identical on both documents.

4. Actual Export Date

Check whether the declaration’s closing date is consistent with the accounting records.

5. Foreign Exchange Follow-Up

Confirm whether any open (unclosed) export file remains and whether bank records are up to date.

6. If an Inward Processing Certificate (DİİB) Applies

For exports made under an Inward Processing Permit Certificate (DİİB), check whether the transaction has been recorded against the export commitment and whether the records required to close the certificate are ready.

7. VAT Refund

Confirming that the GÇB has been closed and that the correct documents have been attached to the refund file is a prerequisite for the VAT refund process to conclude without delay.

Risk Areas to Watch For

Risk areas that deserve particular attention in this process include:

• Incomplete collection: the full export proceeds not having been brought into the country.
• Over- or under-declaration: inconsistencies between the amount declared on the GÇB and the invoice or amount collected.
• Incorrect HS code: misclassification of the goods’ customs tariff position.
• Open foreign exchange file: bank files left unclosed because entry of export proceeds was not completed.
• Overdue export proceeds: proceeds not brought into the country within the legal deadline (as a general rule, 180 days from the actual export date).

Overlooking these risk areas can result in tax penalties, loss of incentives, delayed VAT refunds, and administrative fines under foreign exchange regulations.

Deadline for Repatriating Export Proceeds

Under Communiqué No. 2018-32/48 relating to Decree No. 32 on the Protection of the Value of Turkish Currency, and the CBRT’s Export Communiqué, proceeds from export transactions carried out by residents of Turkey must, as a rule, be transferred or brought in directly and without delay following the importer’s payment. As a general rule, the deadline for repatriating proceeds cannot exceed 180 days from the actual export date. Once the proceeds are brought into the country, banks must issue an İBKB or DAB.

Recommendations for Exporters

• Apply the 7-step checklist in full for every GÇB file.
• Confirm that export proceeds were repatriated within the 180-day deadline and that an İBKB/DAB was issued.
• Regularly monitor any open foreign exchange files and keep your bank records up to date.
• Make sure the GÇB is closed before filing a VAT refund claim.
• Don’t neglect the commitment-closing process for exports made under an Inward Processing Certificate (DİİB).

Customs transactions are among the data sources feeding the AI-powered KURGAN risk analysis system, which makes fully and promptly closing your GÇB files important from this angle as well.

At Mete CPA & Auditing, we support you throughout the entire process — from fully closing your GÇB files and ensuring compliance with foreign exchange regulations, to tracking your VAT refund process and identifying potential risks in advance. Contact us to review your situation.

The KURGAN risk analysis system we covered in an earlier article doesn’t just monitor invoices and e-ledger records — it also closely tracks spending on corporate credit cards. Banking transactions (POS, EFT/wire transfers, credit card payments) are evaluated by risk analysis centers and compared against a company’s commercial activity. In this article, we explain why corporate credit card spending has become such a critical area of scrutiny, and what precautions taxpayers should take.

Why Credit Card Spending Is at the Center of Tax Audits

According to data from the Interbank Card Center (BKM), domestic and international spending on credit cards shows a striking increase every year. Such a large, fully digitally traceable dataset naturally becomes a priority for the tax administration’s risk analysis. Every credit card transaction implies the existence of income that financed it — so inconsistencies between spending and declared income stand out directly in KURGAN’s risk scoring.

Which Expenses Create Risk?

In practice, the most common risk area is recording personal expenses made on company-issued credit cards as business expenses. It is particularly conspicuous when company partners purchase luxury vehicles, home goods, or similar assets for themselves or family members in a manner disproportionate to their official commercial activity. This type of spending can create two distinct risks:

• Tax risk: If the partners have no other income, these amounts may be treated as profit distributed by the company under Article 94/15-b of the Income Tax Law — resulting in a significant tax base adjustment and penalties on both the corporate tax and withholding tax fronts.
• MASAK risk: Acquiring assets disproportionate to one’s official commercial activity may be evaluated under anti-money laundering legislation; if the source of the transaction cannot be established, the Financial Crimes Investigation Board (MASAK) may launch an investigation, and the relevant assets may be seized.

Why Reconciliation with Accounting Records Is Critical

KURGAN cross-checks credit card activity against a company’s e-invoice, e-ledger, and tax return data. For an expense to be accepted as a legitimate business expense, it must:

• Be directly related to the company’s line of business,
• Be supported by a legal document such as an invoice or receipt,
• Be recorded in the accounting books fully and on time.

When these three conditions are not met, the expense may be disallowed and the related VAT deduction rejected; recurring inconsistencies can trigger an Explanation Letter process.

Why Timely Submission of Statements Matters

Submitting corporate credit card statements and related expenditure documents to your CPA within the first week of each month is critical — both for keeping accounting records accurate and timely, and for being prepared in case of a potential Invitation to Explain. Statements submitted late or without adequate supporting documents create time pressure during month-end filing and increase the risk of reconciliation gaps.

Recommendations for Taxpayers

• Use corporate credit cards only for expenses directly related to the business; strictly separate personal spending.
• Obtain an invoice or receipt for every expense and keep these documents together with your statements.
• Submit credit card statements and supporting documents to your CPA within the first week of each month.
• Make sure partners use their personal cards, not the company card, for personal spending.
• Consult your CPA before making large or unusual purchases.

At Mete CPA & Auditing, we help you assess whether your corporate credit card spending is reconciled with your accounting records and identify potential risk areas in advance. Contact us to review your situation.

Turkey’s Ministry of Treasury and Finance has fully digitalized the cross-verification (karşıt inceleme) process used by Sworn-in Certified Public Accountants (YMM), through Communiqué No. 1 on the electronic submission of cross-verification records attached to YMM certification reports, published in the Official Gazette dated December 24, 2025 (No. 33117). In this article, we summarize how the process works, the transition timeline, and the penalties that apply when a response is not submitted on time.

What Is a Cross-Verification Record?

When preparing certification reports — such as full certification or VAT refund reports — YMMs conduct cross-verification to confirm the authenticity of transactions between the taxpayer and the companies it does business with. The records produced through this process form an integral part of the certification report. Under the new regulation, these records are no longer prepared on paper; they are now created, approved, and sent to taxpayers electronically through the Digital Tax Office (dijital.gib.gov.tr).

An important threshold: for 2026, cross-verification is not mandatory for documents with a value (excluding VAT) of up to TRY 150,000.

Transition Timeline

• January 1 – June 30, 2026: Electronic submission is optional; paper records remain valid during this period.
• As of July 1, 2026: Electronic submission becomes mandatory. Cross-verification records prepared on paper after this date cannot be submitted to tax offices; even if submitted, they carry no legal validity and are treated as “never having been prepared.”

This can cause a YMM’s certification report to be considered incomplete and may halt processes such as VAT refunds for the taxpayer — meaning this is no longer solely the YMM’s responsibility to track, but the taxpayer’s as well.

What Taxpayers Must Do: The 30-Day Window

Taxpayers subject to cross-verification must respond to the YMM’s request within 30 days of notification. Responses are treated as an official document signed by the taxpayer or their authorized representative. Taxpayers may also grant sub-user authorization to their accountant (SM/SMMM) under an agency and liability agreement, allowing the accountant to manage this process on their behalf.

What Happens If You Don’t Respond in Time?

Taxpayers who fail to respond to a cross-verification request within the deadline, or who provide incomplete or inaccurate information, are subject to a special irregularity penalty under Article Mükerrer 355 of Tax Procedure Law No. 213. For 2026, this penalty was set at TRY 35,000 for first-class merchants (i.e., corporations) and self-employed professionals under General Communiqué No. 588 on the Tax Procedure Law — and this amount can apply separately to each individual record/transaction. For example, if 20 cross-verification requests go unanswered in a single year, the total penalty can quickly reach hundreds of thousands of lira.

Recent cases also show that objections to tax/penalty notices issued due to late responses are being rejected — underscoring how seriously this process is now being enforced.

The Connection to KURGAN

This digitalization and increased enforcement of cross-verification did not happen in isolation. Viewed alongside the KURGAN risk analysis system covered in our earlier article, it becomes clear that the tax administration is systematically strengthening its ability to cross-check taxpayer declarations against third-party data. Inconsistencies in cross-verification records can directly affect a taxpayer’s KURGAN risk score.

Recommendations for Taxpayers

• Monitor notifications from the Digital Tax Office closely; don’t miss e-notification alerts.
• When a cross-verification request arrives, contact your CPA immediately rather than waiting until close to the 30-day deadline.
• Grant your CPA sub-user authorization so the process can be professionally managed on your behalf.
• Remember that paper records will no longer be valid after July 1, 2026 — make sure your YMM is also prepared for this transition.

At Mete CPA & Auditing, we support you in responding to cross-verification requests from the Digital Tax Office accurately and on time, helping you avoid special irregularity penalties. Contact us to review your situation.