Circular 2025 – 073
New regulations have been made regarding the condition of submitting a CPA approval report in the application of exceptions and discounts.
With the General Communiqué No. 49 on the Law on Certified Public Accountants and Independent Public Accountants, published in the Official Gazette dated December 30, 2025, and numbered 33123; a condition for submitting an independent public accountant's attestation report is introduced for taxpayers subject to income and corporate taxes, for the exemptions and deductions declared in the relevant sections of their tax returns, for the application of reduced tax rates, and for the application of local and global minimum top-up corporate tax, within the framework of the procedures and principles determined.
Accordingly, the compliance of the exemption/discount/application amounts shown in the Declaration with the legislation is aimed to be verified by the CPA's approval. The provisions of the Communiqué will be applied for calendar year users for the year 2025 and subsequent years; for special accounting period users, for the special accounting period starting in 2025 and onwards.
The notification separately specifies the subjects of exemption requiring approval for income tax payers and corporate tax payers.
Exemptions, deductions, and applications that corporate income taxpayers are required to have certified by sworn financial advisors
For the exceptions/deductions listed above and having their own line on the declaration (except for the “Other Deductions” and “Other Exceptions” lines), certification is mandatory if it exceeds TL 500,000.
Although each of these exceptions and discounts does not exceed 500,000 TL, if the total of multiple exceptions/discounts exceeds 1,000,000 TL, it is subject to approval in its entirety.
If the amount written in the “Other Deductions” line in the “Income to be Declared Deductions” section of the declaration, or in the “Other Exemptions” line in the “Notification Regarding Exempt Gains” section, exceeds 1,000,000 Turkish Liras, or if the sum of the amounts written in these two lines exceeds the same amount, all exemptions and deductions must be audited
In the reduced income tax application under Article 32/A of Law No. 5520, tax reduction without a limit is subject to approval.
Exemptions, deductions, and applications that corporate taxpayers are required to have certified by sworn financial advisors
For the exceptions/deductions listed above and having their own line on the declaration (except for the “Other Deductions” and “Other Exceptions” lines), certification is mandatory if it exceeds TL 500,000.
Although each of these exceptions and discounts does not exceed 500,000 TL, if the total of multiple exceptions/discounts exceeds 1,000,000 TL, it is subject to approval in its entirety.
In cases where the amount entered in the “Other Deductions and Exemptions” line under the “Exemptions and Deductions to be Deducted Even if There is a Loss” section of the declaration, or the amount entered in the “Other Deductions” line under the “Exemptions and Deductions to be Deducted If There is Profit” section of the declaration, exceeds 1,000,000 Turkish Lira, or if the sum of the amounts entered in these two lines exceeds the same amount, the approval of all exemptions and deductions is mandatory.
In cases where the exceptions included in the table and the total of other discounts and exceptions exceed 1,000,000 Turkish Lira, the approval of all of them is mandatory.
In the reduced applications of the corporate tax rate within the scope of articles 32, paragraphs 6, 7, and 8 of Law No. 5520, the entire tax relief is subject to audit if the total tax relief utilized exceeds 200,000 TL.
Under Article 32/A of Law No. 5520, the confirmation of calculated amounts without a ceiling is mandatory for the reduced corporate tax application and for the Local and Global Minimum Complementary Corporate Tax applications (Annexes 1-13 and Provisional Article 17).
On the other hand, taxpayers who have their tax returns attested by entering into agreements for the attestation of Corporate Tax returns and their appendices (full attestation) are not required to submit separate reports for the transactions within the scope of attestation, provided that their full attestation reports shall include the matters listed in the report disposition annexed to this Communiqué regarding the relevant deductions, exemptions, or applications in a separate section thereof.
You can access the aforementioned communique, which also includes provisions on the application of report submission deadlines and the matters to be included in the report, via the link below.
resmigazete.gov.tr/eskiler/2025/12/20251230-8.htm
Sincerely
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