Circular 2026-038
Announcement Issued Regarding the Global ATV Declaration and Notification Form
An announcement regarding the Global Minimum Top-Up Corporate Tax Declaration and Notification Form was published by the Revenue Administration Digital Tax Office on 06/16/2026.
The announcement includes explanations regarding the declaration obligations of ultimate parent entities, intermediate parent entities, or partially owned parent entities in Turkey under the Global ATV scope, as well as the notification obligations of subsidiary entities outside this scope.
ANNOUNCEMENT REGARDING THE GLOBAL MINIMUM TOP-UP TAX DECLARATION AND NOTIFICATION FORM
Due to the high demand from taxpayers, the following statements have become necessary.
A. Global ATV Declaration
Under the IIR, the taxpayer is entities affiliated with multinational enterprise groups and located in other countries, concerning a global minimum supplementary corporate tax, which are located in Turkey:;
* The ultimate main operation,
* Main business or
It is a partially owned parent company.
In this context, it is possible for a multinational enterprise (MNE) group to have multiple Ultimate Parent Entities (UPEs) in Turkey, and each UPE must submit a separate GloBE UPE Information Return. However, when determining whether an Ultimate Parent Entity or Partially Owned Parent Entity located in Turkey is subject to the GloBE rules, it is important to consider the provisions in Article 7 of Law No. 5520 and the explanations provided in the General Communiqué on the Application of Local and Global Minimum Top-up Corporate Tax.
It is sufficient for one of the entities within the same CUI group to submit the Global CbCR Information Statement. On the other hand, if the Global CbCR Information Statement is submitted in a country that is a signatory to the “Multilateral Competent Authority Agreement on the Exchange of CbCR Information (GIR-MCAA)”, it is not required to be submitted by Turkish Global CbCR entities.
Global ATV taxpayers, in terms of corporate tax, at their respective tax offices, in their own names “0064 – Global Minimum Corporate Tax” they are required to establish their tax liability and submit the “Global ATV Declaration.”.
In this scope, taxpayers are not obligated to submit the “Global Minimum Top-up Corporate Tax Declaration Form.”.
B. Global ATV Notification Form
Other constituent entities located in Turkey that are not in the main holding company status (Ultimate Parent Entity, Intermediate Parent Entity, and Partially-Owned Parent Entity) listed in Chapter A of the scope of UID groups are obligated to file the “Global Minimum Top-up Corporate Tax Notification Form.”.
“The affiliated enterprises that are obliged to submit the ”Notification Form for the Global Minimum Complementary Corporate Tax” “0064 – Global Minimum Corporate Tax” There are no obligations to establish a taxpayer status or submit a “Global ATV Declaration.”.
“The ”Global Minimum Top-up Corporate Tax Notification Form“ will be submitted through the Digital Tax Office. The aforementioned notification form, in order to ensure that the relevant fields in the ”Global Minimum Top-up Corporate Tax Declaration Information” section are filled out completely and accurately, the Global Minimum Top-up Corporate Tax Declaration after the declaration period (06.30.2026) will be available to businesses required to notify. Therefore, concerning the relevant section of the “Information on the Global CBE Declaration” in the Global CBE Notification Form following the submission of the Global ATV Information Statement in Turkey or abroad it will be possible to fill.
You can also access the announcement through the following link.
Sincerely
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