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Tax Law and Tax Disputes

Tax Obligations of Companies in Türkiye and Liability for Tax Debts (2026)

A meeting table with a Turkish flag and law books, where financial reports and a calculator are used to assess a company’s tax liability
Author: Published: Updated: About 30 min read

Institutional legal review and control: Güneş & Güneş Law Firm

Published by: Güneş & Güneş Law Firm

Summary

Which taxes a company in Türkiye will pay does not depend only on whether it is a joint-stock company, a limited liability company or a sole-proprietor or partnership-type business. Legal type, the nature of the activity, earnings, the supplies and services made, payments to employees and rent payments, the connection of the transaction with Türkiye, exemptions and the capacity of a party responsible for tax are assessed together. In 2026 the general corporate tax rate is 25%; for certain financial institutions and some companies listed in the law it is 30%; the general VAT rate is 20%. However, activities such as export and production may be subject to different rates, certain exemptions and the domestic minimum corporate tax calculation. If tax debts are not paid, a company’s legal personality does not automatically protect everyone: in particular, the liability of limited liability company shareholders for public debts rests on rules separate from the liability of statutory representatives. This guide examines together which tax arises in which event, the 2026 obligations, electronic records, tax inspection and routes of litigation.

The tax assessment begins with the designation under company law, but does not end there. A taxpayer (mükellef) is the person or institution on whom the tax debt arises. A party responsible for tax (vergi sorumlusu), by contrast, may be answerable to the administration because of statutory duties such as withholding, declaring or paying the tax (Tax Procedure Law (VUK), Art. 8). For example, while a limited liability company may be a corporate tax taxpayer on its own commercial earnings, when it withholds income tax from an employee it acts as a party responsible for tax. The person who bears the economic burden of a tax and the person who declares and pays it are not always the same.

Joint-stock company and limited liability company

Joint-stock companies and limited liability companies are capital companies with legal personality; as a rule their earnings are subject to corporate tax. Corporate tax is not separately assessed on the natural person who owns the company merely in that capacity. On the other hand, where a shareholder receives a salary, a dividend, interest or another income from the company, separate taxation may come into question according to the legal nature of that income. Commercial-law liability limited to the capital debt and liability for tax/public claims are not the same thing. The risk of a limited liability company shareholder under Article 35 of Law No. 6183 must be assessed separately.

Natural-person business, general partnership and ordinary limited partnership

The structure called a “sole proprietorship or partnership company” (“şahıs şirketi”) in everyday language sometimes refers to a natural person’s commercial business and sometimes to a general partnership (kollektif şirket) or ordinary limited partnership (adi komandit şirket) regulated in the Turkish Commercial Code (TTK). This distinction matters for taxation. The commercial earnings of a natural-person merchant are determined under the rules of income tax. As regards the earnings of the members of a general partnership and the general partners (komandite) of an ordinary limited partnership, income tax rules may apply at the level of the member; the tax nature of the profit share of the limited partner (komanditer) in an ordinary limited partnership is different. That the company itself has duties such as VAT and withholding does not mean that its earnings make it directly a corporate tax taxpayer.

Limited partnership with share capital and joint venture

A limited partnership with share capital (sermayesi paylara bölünmüş komandit şirket) cannot be treated under the same tax regime as an ordinary limited partnership; in the Corporate Tax Law it is among the capital companies. For taxation purposes, the special provisions on general partners are also taken into account. Certain joint ventures may, where the conditions exist, be treated as falling within corporate tax liability. The concepts of ordinary partnership, commercial company and joint venture in tax law should not be confused with one another.

Cooperatives

Cooperatives are among the institutions within the scope of corporate tax; however, an exemption comes into question if the conditions of Corporate Tax Law (KVK) Art. 4/1-k are met. The exemption does not arise automatically merely because the cooperative “does not distribute profit.” The provisions of the articles of association, the actual activity, transactions with non-members and, for housing cooperatives, special conditions must be examined. For transactions with non-members, there may be special consequences such as a separate economic enterprise attached to the cooperative’s legal personality. Rather than carrying over verbatim all the conditions listed in older practice from the historical text, the current article and communiqué should be taken as the basis. [K1], [K5]

2. Which taxes do companies pay in Türkiye?

Types of tax do not replace one another. A profitable company may, in the same period, have corporate tax, VAT, withholding, stamp duty and other financial obligations arising from certain transactions. If the company is making a loss, a corporate tax base may not arise; even so, VAT, withholding, stamp duty or other payment/notification obligations may continue. The absence of one tax does not show the absence of the others.

Tax or obligationIn which event does it arise?Basic distinction
Corporate taxTaxable earnings of a corporate tax taxpayerGeneral rate 25%; special rates and minimum tax control
Income taxCommercial earnings of natural persons, some shareholder dividends and personal income2026 progressive tariff; regime depends on the income element
VATTaxable supply of goods, services, imports, etc. in TürkiyeGeneral 20%; certain transactions 10%/1% or exempt
Provisional taxPeriodic taxation of the relevant income/corporate earningsSet off against the annual tax; four-period rule in 2026
Income/corporate tax withholdingTransactions listed in the law, such as wages, rent, dividends, professional services or payments abroadWithholding rate by transaction and treaty analysis
Stamp dutyDocuments and transactions that the law taxesNot every contract is taxed at the same rate
ÖTV / ÖİV / BSMVSpecial goods, telecommunications or financial transactionsOnly for activities and taxpayers within scope
Property tax, environmental cleaning tax and other local financial obligationsOwnership of real property, use of a workplace, municipal service, etc.Liability and method of collection vary by type of tax
Social security (SGK) premiumsEmployment of insured workers, the relevant insured statusA social security obligation separate from tax

Does tax arise immediately on the establishment of a company?

Registration with the trade registry matters for the commencement of taxpayer status at the tax office and for electronic notification duties. However, the establishment of a company does not in itself mean that profit has been earned or that a corporate tax debt has arisen. The documents drawn up at establishment, fee/exemption provisions, capital contribution transactions, payment of wages, rent, purchases or the start of activity are examined separately. Even if there is no activity, some periodic returns, notifications and bookkeeping transactions may be mandatory.

3. 2026 corporate tax rates: Which rate applies to which company?

In the table published by the Revenue Administration (GİB) for the 2026 accounting period, the general corporate tax rate is shown as 25%. 30% applies to banks, the groups of financial institutions listed in the law and some public-private partnership (KÖİ) project companies. Reduced rates under certain conditions are as follows:

Type of earnings or institution2026 rateApplication note
General corporate tax taxpayer25%Outside the scope of special rates/reductions
Finance and some PPP (KÖİ)/project companies listed in the law30%Institution type and scope of the law are examined
Earnings arising from export activity20%The reduction concerns not all earnings from activity but the relevant export earnings
Earnings within the scope of an industrial registry certificate and actual production24%Certificate and actual production condition
An institution meeting the condition of a first public offering of at least 20%23%Period and other conditions are checked separately
Public offering + export conditions together18%Calculation of combined applicability and scope
Public offering + suitable production conditions together22%Calculation of combined applicability and scope

Important: The reductions are not applied automatically to the entire base because the company’s name includes “exporter” or “manufacturer.” The separation of export/production earnings, the allocation of expenses, documentary conditions and the special limitations in the legislation must be examined. Detailed and periodic calculation must be made for the first public offering on the stock exchange, investment incentives and other reductions. [K2]

Why does the tax base differ from the accounting profit?

In calculating corporate tax, one starts from the commercial balance sheet profit and then assesses non-deductible expenses, exemptions and deductions, prior-year losses, depreciation, provisions, transfer pricing adjustments and other statutory elements. Corporate tax is not directly 25% of revenue including VAT. In a simplified example, if taxable corporate earnings are TL 2,000,000 and the general rate is 25%, the calculated tax is TL 500,000; this example does not include provisional tax set-offs, exemptions, reductions or the minimum tax control.

Domestic minimum corporate tax: What does 10% mean?

Under KVK Art. 32/C, there is a domestic minimum corporate tax regime for the 2025 and subsequent taxation periods. The basic approach is to compare the ordinary corporate tax, calculated taking into account the exemptions and adjustments listed in the Law, with a 10% limit on the earnings determined before reductions and exemptions. To express this rule as “every company with turnover pays at least 10% of its turnover” is wrong. Exceptions such as exempt institutions and the first three accounting periods of institutions that have just begun activity are examined separately. The calculation of the reduction/exemption base should be checked together with the legislative changes in 2026. [K3]

15% global minimum tax for multinational groups

In the provisions added to the KVK, there is a system of 15% global minimum top-up corporate tax for large multinational enterprise groups. This is not an additional fixed 15% tax applied to all limited and joint-stock companies in Türkiye. Special rules such as the group revenue threshold, the enterprises falling within scope, the effective tax burden by country and safe harbors should be researched. The domestic minimum tax of 10% in Türkiye and the global 15% regime are legally independent institutions. [K1]

The 2025–2027 inflation adjustment arrangement

Under the current temporary provision of the Tax Procedure Law, in the 2025, 2026 and 2027 accounting periods, including provisional tax periods, inflation adjustment is in general not applied to financial statements. There are exceptions for certain taxpayers specifically indicated in the law. This arrangement does not mean that all other tax provisions on depreciation, valuation and inflation adjustment have been abolished. [K4]

4. For which companies and persons does income tax arise?

In natural-person businesses, commercial earnings are, as a rule, subject to income tax as regards the natural person. For the members of general and limited partnerships, the relevant type of partnership and the member’s capacity are decisive. A joint-stock or limited liability company, by contrast, is a corporate tax taxpayer for its own corporate earnings; in addition, it may withhold income tax from employee wages, or a withholding obligation may arise as regards the shareholder’s dividend. The sentence “capital companies never pay income tax” is correct only in the limited sense that corporate earnings are not taxed directly by income tax; the company’s withholding and declaring income tax as a party responsible for tax is different.

The basic brackets of the 2026 non-wage income tax tariff are as follows under Law No. 193, Art. 103 and Communiqué Series No. 332:

Income tax baseRate in the relevant bracket
Up to TL 190,00015%
The portion exceeding TL 190,000, up to TL 400,00020%
The portion exceeding TL 400,000, up to TL 1,000,00027%
The portion exceeding TL 1,000,000, up to TL 5,300,00035%
The portion exceeding TL 5,300,00040%

The bracket rate is not applied to the whole income as a single rate; a progressive tariff applies. The threshold of the third bracket is regulated differently for wage income; wage and commercial earnings examples should not be confused. Special regimes such as exemption, deduction, simplified procedure or craftsman exemption may also come into question. [K6]

5. VAT: When does it arise, and when are deduction or refund possible?

Under Law No. 3065, taxable supplies of goods, performance of services, imports and other transactions in the law within Türkiye may give rise to VAT. The general VAT rate for 2026 is 20%; for certain supplies and services in the lists annexed to the decision, 10% or 1% applies. In determining the rate, what counts is not the type of business but the legal nature of the supply or service. A VAT exemption, in turn, is different from a reduced rate. [K7]

Calculated VAT and deductible VAT

The business compares the VAT it calculates on a taxable sale, under the statutory conditions, with the VAT in properly issued documents for purchases for which the Law grants a right of deduction. In an example where the sale has a net price of TL 100,000 and is subject to 20% VAT, the calculated VAT is TL 20,000. Without examining the existence of deductible VAT, the documentary order, the type of transaction and the period, it cannot be said that “all TL 20,000 is paid to the state.” Non-deductible, carried-forward and refundable VAT are different concepts.

VAT withholding, VAT2 and services received from abroad

Partial or full VAT withholding may apply to certain goods and services. In services received from persons not resident in Türkiye, a VAT declaration as a responsible party may come into question depending on the place of benefit and the nature of the transaction; not every foreign invoice automatically produces the same result. VAT1/VAT2 obligations, the place where the service is performed, the place of benefit, exemptions and the limits of double taxation provisions as regards VAT must be examined together.

Exemption on export and VAT refund

For export supplies, a full exemption and refund of the tax borne may come into question under statutory conditions. However, actual export, customs documents, invoices, the consideration and the link to the transaction, the type of refund and the electronic review processes must be verified. It cannot be asserted that a VAT refund will be made unconditionally or automatically for all exporting companies.

6. Withholding, stamp duty, ÖTV and other taxes for companies

Withholding on wages, rent, professional services and dividends

Withholding is not an independent “company tax” with a single rate for everyone; it is a mechanism of deducting tax at source on payments listed in the law. Different provisions apply to wage payments, workplace rent, certain professional services payments, profit distribution and certain payments to non-resident taxpayers. For example, in workplace rent, whether the lessor is a natural person or an institution, the payer’s withholding obligation and the exceptions may change the result. In a profit distribution, the company’s corporate tax and the shareholder’s income tax are not the same as each other. [K1], [K6]

Stamp duty and contracts

The Stamp Duty Law No. 488 is based on the documents in the table annexed to the law and on its special provisions. It is not correct that stamp duty applies at the same rate to all contracts. Elements such as the exceptions in the law, whether the contract contains a specified sum of money, the maximum amount, the number of copies and the type of signature are taken into account. Exemption/exception provisions should be researched for some company establishments, capital increases and certain investment transactions.

ÖTV, BSMV, accommodation and digital services

Special consumption tax arises only on the relevant transactions in goods specified in the lists of the law. The banking and insurance transactions tax (BSMV) is a special regime for financial transactions. Obligations such as the accommodation tax or the digital service tax depend on the existence of certain activities and statutory thresholds. Not every company is a taxpayer for all of these taxes. Sector analysis should be made separately in fields such as the financial sector, tourism, automotive, energy and the provision of electronic services.

Environmental cleaning tax, property tax and SGK

For workplaces, the environmental cleaning tax depends on the tariff set according to building groups/classes in municipal legislation; it is not the same as the calculation based on water consumption in residences. The 2026 tariff was set by Communiqué Series No. 59. The ownership of the workplace, its actual use and the record with the municipality matter. In property tax, the owner and other liability situations in the law are assessed separately. SGK premiums are not taxes; however, they are a separate and significant public obligation of a company that employs workers. [K8]

7. Which tax obligation arises in which event? Application table

Specific transaction or situationPossible tax consequenceDistinction to be noted
A joint-stock/limited liability company earns commercial profitCorporate tax / provisional taxNot the financial profit but the taxable base; reductions and minimum tax
A natural-person merchant earns incomeIncome tax / provisional taxProgressive tariff and provisions specific to the activity
Sale of goods or services in TürkiyeVATType of transaction; rate or exemption
Payment of wages to a workerIncome tax withholding, stamp duty/exemption, SGKWage base, payroll and exemptions
Renting a workplace from a natural personRent withholding depending on conditionsStatus of the lessor and the payer
Distribution of profit to shareholdersRelevant dividend withholding, tax at shareholder levelDistribution decision, exemption and double taxation
Company obtains consulting from abroadVAT liability and/or withholding reviewPerformance, benefit and tax treaty
Export supplyVAT exemption/refund; reduced corporate tax on relevant earningsDocumented export and separation of earnings
Purchase of real property or a vehicleVAT, fees, ÖTV/motor vehicle tax and other possible obligationsDepends on the nature of the goods and the transaction
Company is inactive or makes a lossProfit tax may not ariseControl of books, returns, notifications, withholding and VAT continues
Liquidation of the company or share transferCapital gain, fees, VAT/corporate tax or liability reviewLegal nature of the transaction, tax period and public debts

This table is not an automatic assessment schedule. Statutory exceptions, exemptions, special transactions and treaties cause the specific result to change.

8. Is a limited liability company shareholder, manager or joint-stock company board member liable for a tax debt?

This is the most critical section for company founders. That the company is itself the debtor with its own legal personality does not mean that natural persons can never be pursued for a public debt. However, treating a person as the debtor of all company taxes merely because they are a “shareholder” may also produce results contrary to law. Shareholding, statutory representation, the period in which the liability arose and the conditions for the collectability of the claim must be separated.

Liability of limited liability company shareholders under Article 35 of Law No. 6183

Limited liability company shareholders may be held liable in proportion to their capital shares for public claims that cannot be collected in whole or in part from the company or that are understood to be incapable of being collected. This is not an authority to impose the entire debt on the company shareholder as the first addressee of a tax assessment; the preconditions in the law and the personal enforcement steps are examined. In a share transfer, there are special rules, such as the joint and several liability of the transferor and the transferee for certain past debts and the fact that the shareholders on the dates when the claim arose/had to be paid may be different. [K9]

Which dates and records matter in the review?

The company’s trade registry, share transfer agreements, share ledger, the date on which the tax arose, its due date, shareholding ratios and collection steps against the company should be assessed in the same table. That a share is not registered in a person’s name at a date after the transfer does not automatically free them from all public debts relating to the earlier period. Conversely, a person who was not a shareholder in the period of the debt cannot be unconditionally charged with a past debt simply because they became a shareholder later; the special transfer rules in Article 35 must be applied concretely.

Liability of statutory representatives and managers

VUK Art. 10 and Law No. 6183 repeated Article 35 are not provisions that regulate the same facts in an identical procedure. The relation of the special law in respect of tax, claims linked to tax and failure to perform tax duties; the application in respect of other public claims and representation liability; and the decisions of the Constitutional Court and current case law must be taken into account. In proceedings against a statutory representative, the time when the authority of representation began and ended, its relationship to the performance of the tax duty, the condition of collection from the company and the act establishing the capacity of personal debtor are examined together. [K10]

Is being a shareholder the same as being a manager?

No. In a limited liability company, a person’s being only a shareholder and their being at the same time the company manager/statutory representative may give rise to different liability regimes. In a joint-stock company, being merely a shareholder does not, as a rule, create the Article 35 liability specific to limited liability company shareholders; however, board membership, authority of representation or another statutory capacity is examined separately. Registration records, authority of representation, term of office and the type of debt are the main evidence.

Liquidation, closure of the company and tax debts

The fact that a company has been liquidated does not mean that past-period tax duties and the liability of the statutory representative disappear by themselves. The period before/after liquidation, the acts of the liquidation officer, closing returns, completion of the liquidation and the procedure for pursuing the public claim must be examined separately. Tax debt and possible inspection risk should be checked before liquidation and shareholding transfer transactions.

9. The 2026 filing and payment calendar and electronic obligations

The annual corporate tax return is, on a normal calendar-year basis, filed between April 1 and 30 of the following year, and the tax is paid by the end of the same month. Indeed, the filing and payment period for the corporate tax of the 2025 accounting period was April 1–30, 2026. The annual return for the 2026 accounting period relates, on the ordinary calendar, to the April 2027 period; the announced calendar and decisions extending time limits must be followed separately. For companies with a special accounting period, the rule of the fourth month following the close applies. [K2], [K11]

Provisional tax: the fourth period is back in 2026

With Law No. 7566, the phrase “determined for the first nine months” was removed from repeated Article 120 of the Income Tax Law. For this reason, in provisional tax for 2026, the last three-month period is also taken into account. The provisional tax periods, the relevant rates, the in-year filing and payment dates, the right of set-off and the provisional tax base should be applied according to the GİB’s period-specific calendar. Carrying the three-period information of previous years over automatically to 2026 would be wrong. [K12]

VAT, withholding and other monthly periods

In the 2026 GİB calendar, the last day for various obligations such as VAT and the withholding/premium and service return may be set, for example, as the 28th of the relevant months, but not every return is subject to the same date. They must be followed in the official tax calendar, taking into account general and special returns, holidays and extensions of time limits, and the taxpayer’s status. Recurring reminders in an accounting program are not, on their own, legal verification. [K11]

e-Invoice, e-Archive, e-Ledger and retention obligations

The e-document obligation varies according to the taxpayer’s activity, turnover, the scope of certain laws and communiqués, and the period. There is no single electronic transition threshold or single mandatory start date for every company. The e-Invoice and e-Archive system, e-Ledger certificates and retention periods, the financial seal/e-signature, change of authorization, technical access and retention obligations must be checked together. The differences between the general five-year retention/production period under the VUK and the regime for the retention of commercial documents in the TTK should be taken into account. The existence of an electronic record system does not remove the obligation to produce records.

Internal checklist for the company for 2026

  1. Verify tax identification/taxpayer and registry records; check beneficial owner notifications.
  2. Draw up an inventory of corporate/income tax, VAT, withholding and special taxes by activity and transaction.
  3. Verify the filing and payment deadline of each period separately in the GİB calendar.
  4. Reconcile invoice, contract, payroll, bank, stock, customs and electronic ledger records.
  5. Review transfer pricing, shareholder current accounts, disguised capital and dividend transactions.
  6. In payments abroad, check the treaty, certificate of residence, nature of the service and VAT liability.
  7. Follow tax inspection letters, electronic notifications and litigation time limits daily.
  8. Report past public debts in the processes of company manager/board of directors and share transfer.

10. How are foreign-owned companies established in Türkiye and companies based abroad taxed?

The presence of a foreign national shareholder does not by itself make a company established in Türkiye a non-resident (limited) taxpayer. Under Article 3 of the Corporate Tax Law, institutions whose legal headquarters or business center is in Türkiye are taxed on a full-liability basis; those whose both centers are outside Türkiye are taxed on a limited-liability basis in respect of the earnings they obtain in Türkiye. A Turkish branch of a foreign company, the shareholding of a foreign natural person in a Turkish company, and a subsidiary established in Türkiye as a separate legal entity are not the same thing. [K1]

Distinguishing branch, subsidiary, liaison office and place of business

A subsidiary established in Türkiye is assessed on its own legal or business center. For the Turkish branch of a company abroad, limited liability and earnings attributed to Türkiye may come into question. A liaison office is subject to the condition of not carrying on commercial activity within the scope of the permission given by the competent authority; if actual activity exceeds the limit of the permission, the tax consequence may change. The assessments “being a foreign company, it pays no tax in Türkiye” or “being a branch, its worldwide income is always taxed in Türkiye” are not correct.

Double taxation treaties

If there is a double taxation treaty to which Türkiye is a party, the provisions on permanent establishment, commercial profits, royalties, interest, dividends and dependent activities may affect taxing rights and the rate. In the application of a treaty, the certificate of residence, beneficiary status, beneficial owner, anti-abuse provisions and the withholding rules of domestic law are addressed together. Treaties are not a source of general automatic exemption for VAT or SGK; the scope of each tax is assessed separately.

In a purchase from another company belonging to a manager or shareholder, an intra-group loan, a transfer of royalty rights, a management service from abroad, or a shareholder current account transaction, an arm’s-length analysis is needed. Under KVK Art. 13, disguised profit distribution, non-deductible expenses, withholding, VAT and criminal risks may arise together. In a dispute, the internal policy, written contract, actual service, evidence of payment and comparable price data are important. [K1]

11. What rights are there in tax inspection, assessment, penalties and collection?

The carrying out of a tax inspection does not in itself show that the offense of tax evasion has been committed. The inspector’s claim as to the tax base may be contested within the framework of material data, legal characterization and the rules of proof. The inspection report, the assessment, the tax/penalty assessment notice and the payment order are different legal acts; the route of litigation and the time limit are also not the same.

Tax loss, irregularities and offenses under VUK Art. 359

Under VUK Arts. 341–344, in the case of tax loss, a penalty linked to the principal tax may come into question. The tax loss penalty is, as a rule, one times the tax lost; where tax loss is caused by acts under VUK Art. 359, the three times rule and other increase/reduction provisions are assessed separately. VUK Art. 359, however, does not make every accounting or declaration error a criminal offense. The perpetrator, the act, the mental element, documents and records, the inspection procedure, effective repentance (etkin pişmanlık) and procedural safeguards are discussed on the specific file. [K4]

Action before the tax court against an assessment

The general time limit for filing suit against a tax/penalty assessment notice is 30 days (İYUK Art. 7); the date of properly effected notification is taken as the basis. The effect on the time limit for suit of a reservation of objection (ihtirazi kayıt), rectification-complaint (düzeltme-şikâyet), settlement (uzlaşma), reduction of penalty and other applications must be assessed under their own special provisions. After the changes made in 2024, the principal tax, like the penalty within the scope of settlement, is not a subject of settlement; the current scope of settlement and the monetary thresholds must be checked separately. [K13], [K14]

Action against a payment order and collection

Under Law No. 6183 Art. 58, an action may be filed against a payment order within 15 days on grounds in the law, such as that the debt does not exist, has been partly paid or is time-barred. Confusing the 30-day time limit for suit against the assessment notice with the 15-day period for the payment order leads to loss of rights. The difference is important between the rule that collection stops when the initial assessment is made the subject of an action and the fact that collection does not stop automatically when an action is filed against a payment order; where necessary, a stay of execution is requested. [K15], [K16]

Attachment, electronic attachment and personal liability steps

Once collection steps have been taken against the company, steps such as electronic attachment of bank accounts, attachment of movable/immovable property, or a payment order in the name of a representative/shareholder may arise. In these steps, notification, the conditions of collection, the periods of the debt, the limitation period for collection, the capacity of the person pursued, transactions made in the company and authority must be separately reviewed. That there is a final debt against the company does not lead to the conclusion that a personal payment order is lawful in every case.

Scenario A: The limited liability company made a loss but a VAT debt arose

The company’s commercial result may be a loss; but because of taxable sales and the VAT deduction system, VAT payable may have arisen in a period. Wage withholding, SGK and other debts may also arise. A loss does not eliminate all public debts.

Scenario B: A limited liability company shareholder transferred their share; a past tax debt is demanded

The period in which the public claim arose and fell due, the legal date of completion of the share transfer, the share ratios, the possibility of collection from the company and the special provisions of Article 35 for the transferor/transferee are examined together. The current shareholder list alone is not sufficient.

Scenario C: A payment order was sent to a joint-stock company board member

Before whether the person is a shareholder, the authority of representation, the term of office, the type of debt and the VUK Art. 10/Law No. 6183 repeated Article 35 regime are examined. It cannot be said that all debts are automatically the person’s personal debts merely on the ground that “they were on the board.”

Scenario D: A foreign company provided software services to a Turkish customer

The nature of the service, the formation of a place of business in Türkiye, limited liability and withholding under domestic law, the place of benefit for VAT, the relevant treaty and the invoicing arrangement may lead to different results. It is not correct to reduce the possibilities to a single rule that “a foreign invoice is tax-free.”

Scenario E: The company received several penalties after a tax inspection

The report, findings by act, documents, periods, the statutory conditions of the tax loss and special irregularity penalties and, where necessary, the criminal investigation documents must be examined separately. An administrative penalty and criminal liability under VUK Art. 359 are not subject to the same procedure and standard of proof.

13. Conclusion: Correct tax planning begins not with the company type but with the specific transaction

The tax obligations of companies in Türkiye extend beyond the company type chosen at establishment. The corporate or income tax base, the transaction giving rise to VAT, the withholding obligation, electronic filing, transactions abroad, authority of representation and the procedure for collecting the public debt must be kept apart from one another. In 2026, because of the special provisions on corporate tax rates, the domestic minimum tax, the fourth provisional tax period and inflation adjustment, using old information unchanged is risky. It should especially be remembered that in a limited liability company, the capacities of shareholder and manager give rise to tax liability separately. When a tax inspection or a payment order arrives, the type of the act and the date of notification are the first checkpoint; an assessment made within the time limit preserves the possibility of seeking a remedy.

14. Frequently Asked Questions

1. What is the 2026 corporate tax rate for a limited liability company in Türkiye?

The general rate is 25%. However, special or reduced rates and the domestic minimum corporate tax calculation may apply in the sectors listed in the law and to the relevant earnings. A single rate is not applied automatically to every company.

2. If a company makes a loss, does it pay no tax at all?

No. Although corporate/income tax on profit may not arise, VAT, withholding, stamp duty, SGK and other obligations may arise according to the transactions. Notification and filing duties may also continue.

3. Must a limited liability company shareholder pay the company’s tax debt from their own assets?

If the conditions in Law No. 6183 Art. 35 are met, liability in proportion to the capital share may arise for a public claim that cannot be collected from the company or is understood to be incapable of being collected. If there is also a capacity as manager/representative, separate provisions are also assessed.

4. Is a person who is merely a shareholder in a joint-stock company liable for all tax debts?

As a rule, no. Mere shareholding does not give rise to the Article 35 regime specific to limited liability companies. However, the subscribed capital debt, statutory representation and other special grounds of liability are examined separately.

5. Does a company manager’s leaving office remove past tax liability?

Not always. The period of the debt, the duration of the authority of representation, the unperformed tax duty and the conditions of personal pursuit are decisive. Registration and notification documents matter.

6. Is corporate tax paid as soon as a company is established?

Establishment does not by itself give rise to taxable profit. However, the commencement of taxpayer status, documentary and notification obligations, transactions connected with establishment and taxes that arise later are taken into account.

7. Does a company withhold income tax from its employees?

It may carry out income tax withholding on wage payments under statutory conditions; exemptions and exceptions are taken into account. Wage withholding is not the company’s own corporate tax.

8. Is the VAT rate 20% on all sales in 2026?

No. Although the general rate is 20%, 10% or 1% applies within the lists annexed to the decision, and an exemption or special regime applies to some transactions. The goods or service must be classified correctly.

9. Does an exporting company pay 20% corporate tax on all its earnings?

No. The reduced rate applies to earnings from export activity that meets the conditions in the law; other earnings may be classified separately.

10. How many provisional tax periods are there in 2026?

Because of the amendment made by Law No. 7566, the fourth provisional tax period is again within scope. The filing and payment date of each period should be checked in the GİB calendar.

11. Are companies’ foreign-source incomes taxed in Türkiye?

For a resident taxpayer institution whose legal or business center is in Türkiye, worldwide earnings are, as a rule, within the scope of taxation; double taxation treaties, foreign tax credit and exemptions are assessed. For a non-resident taxpayer, the limit of Türkiye-source earnings is the basic distinction.

12. Is there withholding and VAT on a foreign consulting invoice received by a company?

It varies by transaction. The nature of the service, the place of performance/benefit, the status of the other party, the treaty, residence and the provisions of domestic law must be examined together.

13. Within how many days is an action filed against a tax assessment notice?

The general rule is 30 days. The proper notification of the assessment notice, special applications and their effects on statutory time limits must be checked separately.

14. Is the time limit for suit against a payment order also 30 days?

No. Under Law No. 6183 Art. 58, the general period is 15 days. Filing an action against a payment order does not stop collection automatically; in an appropriate file, a stay of execution should be requested.

15. Is it sufficient for the offense of tax evasion that the tax was merely underpaid?

No. The specific acts and the conditions of criminal liability defined in VUK Art. 359 must occur. The tax loss penalty and criminal proceedings are different legal assessments.

16. Are e-Invoice and e-Ledger mandatory on the same date for every company?

No. The type of activity, annual revenue, special regulations and the transition-period legislation matter. Document, retention and technical obligations must be checked separately.

17. Can a person insured with SGK in Türkiye also set up a sole-proprietor business?

As a rule, being insured and working does not by itself prohibit setting up a commercial business; however, the employment contract, the non-compete rule, professional status, social security overlaps and special permission conditions must be examined separately. Tax and SGK status are assessed independently of each other.

18. Where does a company query its tax debts and returns?

Records relating to accruals, payments, e-notifications and returns can be viewed by an authorized user through the Digital Tax Office of the Revenue Administration (GİB). Authorization and representation records must be kept current.

K1. Corporate Tax Law No. 5520 (5520 sayılı Kurumlar Vergisi Kanunu): GİB legislation text.

K2. GİB, Filing of Corporate Tax, 2026 rates and the April filing period: GİB guide.

K3. KVK Art. 32/C, domestic minimum corporate tax: GİB article.

K4. Tax Procedure Law No. 213 (213 sayılı Vergi Usul Kanunu), inflation adjustment, procedure and penalty provisions: GİB legislation.

K5. Corporate Tax General Communiqué Series No. 1 (1 Seri No.lu Kurumlar Vergisi Genel Tebliği) (cooperative exemption and transactions with non-members): current GİB communiqué.

K6. 2026 Income Tax Tariff, Communiqué Series No. 332 (332 Seri No.lu Tebliğ): GİB 2026 tariff.

K7. VAT rates decision, current lists: GİB.

K8. 2026 Environmental Cleaning Tax, Communiqué Series No. 59 (59 Seri No.lu Tebliğ): GİB.

K9. Law No. 6183 on the Procedure for the Collection of Public Claims (6183 sayılı Amme Alacaklarının Tahsil Usulü Hakkında Kanun), Art. 35: GİB legislation.

K10. Law No. 6183 repeated Art. 35 and the liability of statutory representatives: GİB legislation, collection communiqué.

K11. Revenue Administration (GİB) Tax Calendar: current calendar.

K12. Law No. 7566 (December 19, 2025, Official Gazette 33112), Provisional Tax Amendment: GİB text of the law.

K13. Administrative Procedure Law No. 2577 (2577 sayılı İdari Yargılama Usulü Kanunu): GİB legislation.

K14. Post-assessment settlement after 2024: official GİB brochure, 2026 VUK Supplementary Art. 1.

K15. Time limit for suit against a payment order: official GİB brochure.

K16. İYUK Art. 27/4, distinction on stopping of collection: GİB text of the law.

AUTHOR

Av. Umut Güneş

Güneş & Güneş Law Firm

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