The Turkish government has formalized implementation guidelines for a new minimum corporate tax system targeting large multinational corporations operating in the country, according to an official announcement published in the country's Official Gazette.
The Treasury and Finance Ministry's Revenue Administration issued a comprehensive General Communique on Local and Global Minimum Complementary Corporate Tax Implementation, establishing the procedural framework for the tax regime that applies to qualifying multinational enterprise groups.
The communique outlines the scope, taxpayer obligations, tax base, rate, calculation methods, exemptions, declaration and payment procedures, and transitional period provisions for the minimum tax. The guidelines incorporate standards from OECD Model Rules and Commentary, as well as Administrative Guidance documents developed through international coordination.
The minimum tax system applies to multinational enterprise groups whose annual consolidated revenue exceeds €750 million ($883.27 million) in at least two of the previous four accounting periods. Under the framework, these corporations face an additional taxation mechanism designed to equalize their effective corporate tax rate to a minimum of 15% on profits earned in jurisdictions where they operate.
The tax regime was originally established through amendments to the Corporate Tax Law enacted last year, creating both local and global minimum complementary corporate taxes to ensure qualifying multinational groups pay a baseline level of corporate taxation.
The regulations take effect for profits earned during the 2024 accounting period and subsequent years. The communiqué provides detailed examples and explanations to guide corporate compliance with the new requirements, addressing various scenarios multinational groups may encounter when calculating their tax obligations under the system.
The minimum corporate tax framework represents Türkiye's adoption of international tax standards aimed at preventing profit shifting and ensuring large multinational corporations contribute tax revenue in jurisdictions where they generate income, regardless of where they book profits for accounting purposes.
The 15% minimum rate reflects the global tax agreement negotiated among more than 130 countries through the OECD's Base Erosion and Profit Shifting (BEPS) project. That international framework seeks to address concerns that multinational corporations exploit mismatches between national tax systems to minimize their overall tax burden, often shifting profits to low-tax jurisdictions while conducting substantial economic activities elsewhere.