Global Minimum Tax in Turkey: Rules for Multinational Groups

Turkey has implemented the OECD/G20 Pillar Two framework through local and global minimum top-up corporate taxes. The rules target multinational enterprise groups whose consolidated revenue reaches the EUR 750 million threshold and are designed to bring the effective tax burden in each jurisdiction to at least 15%, subject to detailed adjustments, exclusions and safe harbours.

This guide reflects the official framework checked on 29 September 2026, including Law No. 7524, the Turkish implementation communiqué published on 26 December 2025, the 2026 filing materials and Presidential Decision No. 11511 on recognised jurisdictions. It is written for foreign-parented groups with Turkish subsidiaries or permanent establishments and Turkish-parented groups operating abroad.

What is Turkey’s global minimum tax?

The Turkish legislation uses the term Asgari Tamamlayıcı Kurumlar Vergisi, or minimum top-up corporate tax. It contains two connected regimes:

Which groups are in scope?

A group must first be multinational: it must have at least one entity or permanent establishment outside the jurisdiction of its ultimate parent entity. A wholly domestic group is outside the Pillar Two scope even if it has substantial revenue.

The revenue test looks to the ultimate parent entity’s consolidated financial statements. The group is generally within Turkey’s rules for a fiscal year when annual consolidated revenue was at least EUR 750 million in at least two of the four immediately preceding fiscal years. The current year’s revenue is not part of that four-year test. Special rules apply to newly formed groups, short periods, mergers, demergers and acquisitions.

Entities that may be excluded

The Turkish framework identifies excluded entities such as government entities, international organisations, non-profit organisations and pension funds. An investment fund or real estate investment vehicle is excluded when it is the ultimate parent entity and meets the statutory conditions. Certain entities owned by excluded entities can also qualify under detailed ownership and activity tests.

An exclusion is not established by an entity’s label alone. The ownership chain, purpose, activities, income profile and consolidation treatment must be reviewed. Investment entities, joint ventures, minority-owned subgroups, stateless entities and permanent establishments may also require separate calculations.

How the 15% calculation works

Pillar Two is a jurisdiction-by-jurisdiction calculation. The group generally aggregates the GloBE income or loss and adjusted covered taxes of constituent entities located in the same jurisdiction, while certain entity categories are calculated separately.

A simplified example

Assume the Turkish jurisdiction has EUR 100 million of net GloBE income and EUR 12 million of adjusted covered taxes. Its jurisdictional effective tax rate is 12%. If the eligible substance-based income exclusion is EUR 20 million, excess profit is EUR 80 million. Before other adjustments, the top-up amount is EUR 2.4 million: EUR 80 million multiplied by the 3% top-up percentage.

This is deliberately simplified. Real calculations can change because of deferred tax recapture, tax-credit classification, permanent establishment allocations, prior-year adjustments, ownership percentages, domestic top-up tax and safe harbours.

2026 substance-based income exclusion rates

For fiscal years beginning in 2026, Turkey’s transition schedule uses 9.4% of eligible payroll costs and 7.4% of the net book value of eligible tangible assets. The exclusion is commonly called the routine profits or substance-based income exclusion. It does not reduce covered taxes; it reduces the amount of net GloBE income exposed to the top-up percentage.

Eligible payroll generally includes qualifying remuneration, employer social-security contributions and certain employee benefits for employees performing activities in the jurisdiction. Tangible assets generally use an average net book value under the applicable financial accounts. Location, allocation, leases, impairment, revaluation and permanent-establishment rules can materially affect the result.

De minimis exclusion and safe harbours

A jurisdiction may qualify for the de minimis election when the multinational group’s three-year average jurisdictional revenue is below EUR 10 million and its three-year average jurisdictional income is below EUR 1 million. Both conditions must be met, the election is annual and special rules apply to short periods and entity groupings.

For 2026, the transitional CbCR safe-harbour simplified ETR test uses a 17% transition rate under the Turkish communiqué. OECD guidance has continued to evolve, including the January 2026 Side-by-Side package and September 2026 Administrative Guidance. An OECD publication does not by itself amend Turkish filing law: groups should apply Turkey’s legislation, communiqué and recognised-jurisdiction decision while monitoring further domestic implementation.

Turkey filing and payment deadlines

A Turkish filing may include the global minimum tax return, the GloBE information return and a notification identifying the entity that filed the information return in another jurisdiction. Central filing can remove a local information-return filing only when statutory conditions, a qualifying exchange arrangement and the notification requirements are satisfied.

For the local top-up tax, a multinational group may authorise one Turkish constituent entity to file and pay for the Turkish members. The return must still identify the relevant entities separately, and joint liability can continue if the authorised entity does not pay the full amount. General monthly and annual obligations remain separate; the site’s Turkey tax filing and payment calendar explains the ordinary compliance cycle.

Data a Turkish constituent entity should prepare

The calculation begins with consolidated reporting data but cannot be completed from a group tax provision alone. A Turkish entity should be able to reconcile each reporting layer:

• ultimate parent entity, ownership chain and constituent-entity list;

• accepted financial accounting standard and consolidation package;

• Turkish statutory ledger and trial balance mapped to the group chart of accounts;

• current and deferred tax movements, including loss carry-forwards and recapture items;

• tax credits, incentives, grants and refundable-credit classifications;

• covered-tax allocations involving dividends, controlled foreign companies and permanent establishments;

• eligible payroll, employee location and tangible-asset registers;

• Country-by-Country Report, Master File and qualified financial statements used for any safe harbour; and

• filed returns, elections, authorisations, receipts, accrual slips and payment evidence.

Related-party adjustments can change both income and covered taxes. The Turkish entity should therefore align its Pillar Two workstream with its transfer pricing documentation, intercompany agreements and year-end true-ups.

How tax incentives interact with Pillar Two

A Turkish exemption, reduced corporate tax rate or tax credit can be valid under domestic law yet lower the jurisdictional effective tax rate for Pillar Two. The cash benefit may therefore be partly offset by Turkish domestic top-up tax or a foreign IIR or UTPR charge. The accounting classification of a credit—particularly whether it is a qualified refundable tax credit—can also change the GloBE result.

Investment modelling should show both the ordinary Turkish corporate tax outcome and the Pillar Two outcome. The broader Turkey tax and accounting guide for foreign investors explains how incentives, bookkeeping and cross-border controls fit into the operating model.

2026 compliance roadmap

1. Confirm scope. Retain the four-year revenue test, ownership chart and list of excluded entities.

2. Map Turkey. Identify subsidiaries, branches, joint ventures, minority-owned groups and permanent establishments.

3. Assign governance. Name the group data owner, Turkish filing entity, reviewers and signatories.

4. Build the data bridge. Reconcile consolidation, statutory accounting, corporate tax, deferred tax, payroll and fixed assets.

5. Run parallel calculations. Test local top-up tax, IIR/UTPR exposure, de minimis relief and each available safe harbour.

6. Validate recognised jurisdictions. Use Presidential Decision No. 11511 and subsequent Turkish updates—not only an overseas or OECD list.

7. Document elections. Keep source data, assumptions, approvals and calculation versions in an audit-ready file.

8. File and prove payment. Retain the electronic submission receipt, accrual and payment document for each Turkish obligation.

Official sources

• Official Gazette — Law No. 7524

• Turkish Revenue Administration — General Communiqué on Local and Global Minimum Top-up Corporate Tax

• Turkish Revenue Administration — Global minimum top-up tax return and notification materials

• Turkish Revenue Administration — Tax Procedure Law Circular No. 203

• Official Gazette — Presidential Decision No. 11511 on safe-harbour and qualified-rule jurisdictions

• OECD — Global Anti-Base Erosion Model Rules, Commentary, Administrative Guidance and GloBE Information Return

Reviewed on 29 September 2026. This article provides general information and does not constitute tax or legal advice. Pillar Two outcomes depend on the group structure, financial accounts, elections, recognised jurisdictions and facts of each reporting period.