Circular 2026-037
Deadline for Country-by-Country Reporting Notification Form: 06/30/2025
As is known, in the regulations made with the General Communiqué on Disclosure of Gains through Transfer Pricing No. 4, published in the Official Gazette dated 01.09.2020, companies were imposed the obligation to perform Country-by-Country Reporting and to make notifications regarding Country-by-Country Reporting.
The regulation made by the Communiqué Amending the Communiqué on Attribution of Hidden Income Through Transfer Pricing (Serial No: 1), published in the Official Gazette dated 17/10/2024 and numbered 32695, stipulates that the notification form for country-by-country reporting, which is within the scope of transfer pricing documentation obligations, shall be submitted by the end of the sixth month following the end of the accounting period to be reported. Accordingly, it has been clarified that taxpayers with special accounting periods are also required to submit it by the end of the 6th month following the end of the accounting period to be reported.
According to this, by members of multinational enterprise groups (consolidated group revenue of the prior accounting period to the reported accounting period is 750 million euros or more) that fall within the scope; information regarding whether they are the ultimate parent entity or surrogate entity, which entity will report on behalf of the group, and the accounting period, shall be submitted annually by the end of June of the year following the reported accounting period, in accordance with the disclosures available on the Internet Tax Office.“Country-based reporting notification form”will be submitted electronically through the Internet Tax Office by filling it out.
For the year 2025, a company in Turkey that is part of a multinational business group using the calendar year as its accounting period, and whose ultimate parent is not located in Turkey but is within the scope, must notify the Administration via the Internet Tax Office by June 30, 2026, as to which company will prepare the report and in which country.
Taxpayers subject to a special accounting period must electronically submit the said notification form via the Digital Tax Office by the end of the sixth month following the end of the accounting period to be reported.
In case of non-fulfillment of the obligation, the special irregularity provisions stipulated in Article 355 of the Tax Procedure Law will be applied to taxpayers.
Sincerely
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