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Tax Law and Tax Disputes

Deferral and Instalment Payment of Tax Debts: Financial Position, Security, Interest and Keeping the Payment Plan

Payment calendar, money and a document illustrating the deferral and instalment payment of a tax debt
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Institutional legal review and control: Güneş & Güneş Law Firm

Published by: Güneş & Güneş Law Firm

Summary

Instalment payment of a tax debt does not mean the debt is erased automatically or that every application will be accepted.

Instalment payment of a tax debt does not mean that the debt is erased automatically or that every application will be accepted. In 2026 the rules on the deferral period and on security have changed, and a special application route at low interest has been opened for certain debts. Under this special arrangement, the last day to apply is August 31, 2026. A route whose time has passed should not be presented today as if it were an open campaign. For details, see the article on limitation periods for tax debts.

Deferral (tecil) is neither the erasure of a tax debt nor the annulment of the act under dispute. It is the competent administration's postponement of payment of the debt for a set period and on set conditions, after it has assessed the statutory requirements. Filing an application does not show that the request has been accepted.

General deferral and the special arrangement are different

Article 48 of Law No. 6183 on the Procedure for Collecting Public Receivables provides for deferral where payment when due, or attachment and sale, would place the debtor in a very difficult situation. It applies upon a written request and on the statutory conditions, and the competent administration must assess the matter. Filing an application alone does not result in acceptance, a definitive halt to enforcement proceedings or the release of security. For details, see lifting an electronic attachment (e-haciz) for a tax debt.

By Law No. 7582, the general maximum deferral period was raised to 72 months. This upper limit does not mean that every taxpayer will receive 72 monthly instalments. The type of debt, financial position, the authority's competence and special application limits are each examined separately. Under the 2026 security rule, the threshold for deferral without security was raised to 10 million TL; for the part above it, a rule of security at half the rate applies. The calculation takes into account the total debt to be deferred at the relevant collection office. [1; Article 48 of Law No. 6183; Presidential Decision No. 11414]

Scope of the low-interest special arrangement

The guide explains the special arrangement for eligible debts that fell due on June 5, 2026 or earlier and were still unpaid as of June 16, 2026. The application is expected to be made by August 31, 2026. The special arrangement carries a deferral interest rate of 29%; not all tax debts and not all dates fall within the same scope. Excluded items, such as special consumption tax (ÖTV) and the 2026 provisional tax, are checked separately.

Anyone who wants to apply today must first determine whether an application was already made within the deadline. If there is no such application, it is not assumed that a new application can be made under the special program's conditions; the general deferral or another arrangement in force is examined instead. If a new extension decision exists, its official text must be shown separately.

Setting the deferral period according to the taxpayer's financial position

Under the special arrangement, periods of up to 36, 48 or 72 months are provided depending on the liquidity assessment; for some debts, such as value added tax (KDV) and BSMV, shorter limits apply. Special rules for municipalities are also not treated as the same as the general company example. It is important that the financial status declaration be consistent with the actual balance sheet and cash flow.

For example, a debtor may have large receivables but weak short-term payment capacity. Instead of submitting to the administration only a statement that there is no cash, the collectability of receivables, inventory, bank balances and short-term debts should be documented. The condition of severe hardship is different from an abstract declaration of difficulty.

Security conditions and financial documents to attach to the application for deferral of tax debts

ItemData to prepare
Debt inventoryTax type, due date, principal and accessory amounts
Previous stepApplication date, acceptance letter and current plan
Financial positionLiquidity calculation, balance sheet and payment capacity
SecurityType, value, ownership and attachment details
StandingCapacity as principal debtor, representative, shareholder or heir

Where there are debts owed to more than one tax office, it should not be assumed that everything can be completed with a single application. The relevant offices and debt items are tracked separately. Where a debt is pursued on the basis of liability as a shareholder of a company or as its legal representative, the person's own capacity and liability conditions are assessed separately. For details, see the section on objection to a tax payment order.

Payment under an accepted deferral plan and keeping the plan valid

The instalment, interest and payment conditions in the deferral acceptance letter are binding. The breach-remedy provisions of the special arrangement do not give an unlimited right to delay. Conditions such as the permitted number of late instalments in a year being paid with interest within the stated follow-up period are considered together. Failure to keep to the plan may affect the collection and interest outcome for the remaining debt.

The effect of the deferral on a certificate of no debt, a vehicle sale or a public tender is also checked separately. Instalment payment of a debt does not produce the same result as full payment in every transaction. In particular, a vehicle inspection and a vehicle transfer may not be subject to the same conditions.

If the application is rejected, does the debt disappear?

No. The rejection decision and the collection process are assessed separately. The effect of the application on litigation and time limits should be assessed on the basis of the relevant act and ruling, not on assumptions.

Does new interest apply automatically to an existing deferral plan?

The guide provides for interest adjustment for certain existing plans from June 16, 2026. Extension of the period, however, may be made subject to a separate application requirement. A change in interest and an extension of the term are not the same transaction.

Effect of an existing attachment and security

A deferral request does not automatically lift an existing attachment. The value of property already attached, the new security requirement and the administration's assessment are considered together. Deferring a debt in instalments and lifting an attachment on property are separate procedures. Where an attachment over property needed for ongoing business activity is at issue, the request and documents must be prepared separately.

The application should set out realistically the debt list, cash flow, assets, collectability of receivables and the proposed instalment plan. In the assessment of severe hardship, it matters whether an apparent asset can be converted into cash immediately. The type and value of the security must also be acceptable; a market value stated by the debtor is not automatically accepted by the administration.

Certificate of no outstanding debt, vehicle inspection and vehicle sale

For a deferred debt, the content of the debt status certificate is assessed in light of regular payment of instalments and the special conditions of the relevant transaction. Deferring a debt in instalments does not mean that a certificate of no debt can be obtained unconditionally for any purpose. A no-debt condition required for a tax reduction, a public payment or another transaction is also assessed separately.

For motor vehicles, the conditions for technical inspection (fenni muayene) and for sale or transfer are not the same debt conditions. A facilitation relating to inspection does not mean that the vehicle can be transferred freely without its debts being closed. The vehicle and the debt type should be matched in the deferral file; traffic fines, motor vehicle tax (MTV) and other public receivables may fall under different special rules.

Instalment default and a new application

If one instalment is not paid on time, the matter is assessed under the breach provisions of the acceptance letter and the applicable notification. The tolerances of the general deferral and of the special application program that expired in 2026 should not be carried over to each other. If the interest rate changes, the rate applicable to each period is calculated by date.

The fact that a new deferral request may be possible after a breach does not mean that the earlier right is automatically revived. The administration's new assessment, the taxpayer's situation and the collection process are also important. If a refund claim is expected to be set off against the debt, the set-off should be followed through to completion, and not relied on through the refund petition alone.

Decision to make and file to prepare before acting

Set out the debt types and due dates together with the financial status documents. Check the security requirement, the deferral interest and the status of existing attachments. While following the accepted plan, separately assess the effect of new debts and delayed instalments on the plan.

  1. Guide on Instalment Payment of Tax Debts Owed to Tax Offices with Low-Rate Deferral Interest (Vergi Dairesine Olan Borçların Düşük Oranlı Tecil Faizi ile Taksitlendirilmesi Rehberi)
  2. Revenue Administration (Gelir İdaresi Başkanlığı, GİB): Deferral and Instalment Payment under Article 48 of Law No. 6183 (GİB: 6183 m.48 tecil ve taksitlendirme)

AUTHOR

Av. Umut Güneş

Güneş & Güneş Law Firm

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