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2026/12 New; Tax Incentives need to be certified by a Sworn Tax Advisor report

We are pleased to share with you the latest developments in Turkish tax and fiscal system through our monthly bulletins. In this edition, you can find information regarding the new necessary tax certification regime with their effects on your business. Hope you enjoy reading.

Following the recent regulatory updates by the Republic of Türkiye Ministry of Treasury and Finance (General Communiqué No. 49), a significant revision has been introduced regarding tax compliance and reporting obligations for taxpayers operating in Türkiye. This note summarizes the transition from a "declaration-based" system to a "certification-based" system to benefit from certain tax advantages and the necessary steps your company must take.

1. The New Certification Requirement

Starting from the 2025 fiscal year, companies wishing to benefit from tax exemptions, deductions, tax rate advantages and incentives in their corporate & income tax returns are now required to have these benefits audited and approved by a Sworn-in Certified Public Accountant (sworn-in CPA referred to as “YMM” in Türkiye).

The Ministry now requires an independent "Certification Report" to verify that the companies meet all legal criteria to benefit from these tax advantages during the filing of the related corporate or personal income tax declaration. Without this YMM report, any tax deductions and exemptions requested in these declarations will be invalid.

2. The “Full Certification” (Tax Compliance) Agreement

The most efficient way to comply with this regulation is to have a "Full Certification Agreement" with a sworn in CPA. Please see below some particular facts about this regime in Turkiye:

• Standardized Template (Non-Negotiable): It is important to note that the tax certification agreement is a statutory legal template prescribed by the Ministry of Treasury and Finance.
• No Modifications Permitted: The wording, terms, and structure of the contract are fixed by the Ministry. Neither the company nor the YMM has the authority to modify, add or delete clauses within this standard contract, however additional clauses (not contradicting with this template) may be agreed between parties. It must be signed and registered in the Ministry’s system in its original, official form. It can be filled online as well.
• Comprehensive Coverage: Having a Full Certification Agreement (which implies that the YMM reviews and certifies the corporate tax base and the underlying statutory accounts that are declared to the tax office) generally covers the reporting requirements for all tax exemptions and deductions, providing a "safe harbor" for the company’s tax declarations. You can find below some of the necessary tax exemptions or items that have been mentioned in the new tax Communique, number 49.
  • Emission Premium Earnings Exemption
  • Technopark, R&D and Design Center Tax Credit System
  • Interest Deduction Arising from Cash Capital Increase (Notional Deduction)
  • Foreign Subsidiary Earnings Exemption
  • Foreign Subsidiary Share Sale Gains Exemption
  • Real Estate Investment Funds or Partnerships Earnings Exemption
  • Free Zones Exemption in Corporate Tax
  • Exemption Software, Engineering, Training and Healthcare Services Provided Abroad
  • Foreign Construction, Repair, Assembly and Technical Services Earnings Exemption
  • Patent Box Regime
  • International Shipping Profit Exemption
  • Pillar II Top Up Tax Calculation

3. Critical Deadline: January 31

To ensure that your company is protected under the Full Certification regime for the 2026 fiscal year, the agreement must be signed and electronically registered no later than January 31, 2026. Sworn in CPA should audit the whole tax transactions before year end. As the provisional tax return period for the fourth quarter started this year again, February 17th is an important deadline to review the files.  

4. Consequences of Non-Compliance

Failure to sign the sworn in CPA agreement or submit the required certification reports within the legal timeframe results in severe financial consequences:

• Forfeiture of Tax Benefits: The Ministry will treat the absence of a report as a waiver of your rights. All tax exemptions and deductions claimed will be canceled.
• Tax Assessments and Penalties: The “saved” tax amounts will be recovered by the Ministry of Finance, along with “tax evasion penalties” and late payment interest.
• Administrative Fines: Failure to fulfill notification obligations will result in an additional penalty of 410,000 TL for procedural irregularities.

Summary & Recommendation: To protect your company's tax efficiency and ensure full compliance with Turkish law, we strongly recommend that you complete the standard Full Certification Documentation Agreement before January 31st of the related year.

Statistics: There are 1,1 million corporate taxpayers in Türkiye. Approximately 40 thousand of them are subject to the IFRS audit and same figure is subject to sworn in CPA tax audit mostly voluntarily. Different to the IFRS audit, you can consult with sworn in CPAs in financial matters.  

Value Proposal: There are more than 5 thousand sworn in CPA (YMM) and more than 100 thousand CPA (SMMM) who can do the bookkeeping. In Turkish system CPA can do the bookkeeping and sworn in CPA is able to audit those books and records in terms of tax / fiscal legislation in our country.

It means both normal CPA’s and sworn in CPA’s should work together on the same files and taxpayers. There is no conflict or double cost in this working system. We believe that both professions have their own unique expertise, style and business environment and they can create more value to collaborate systematically.

Best regards,

Taxademy Partners