Anasayfa
Intern
Uluslararası
İrtibat
Circular No: 2025 / 83
Date: 05.12.2025
As you know, the Law No. 7524 dated 28 July 2024 added the heading “Local and Global Minimum Top-Up Corporate Tax" to the Corporate Tax Law No. 5520. This regulation entered into force on 02.08.2024 and applies to profits generated in 2024 and following fiscal periods and for entities with a special accounting period to fiscal periods starting in 2024.
According to the information provided in the law, the subject of the tax is the scope of the tax includes multinational enterprise groups whose ultimate parent entity reports consolidated revenues exceeding the Turkish lira of 750 million euros in at least two of the four fiscal years (2023, 2022, 2021, and 2020 will be considered account for 2024.) following the reporting period. Whether a company is within the scope will be checked using the data in the consolidated financial statements prepared by the ultimate parent entity. Therefore, it is important to ensure information sharing with the ultimate parent entity.
The purpose of the Local and Global Minimum Top-Up Corporate Tax is to ensure that, for each country in which the group operates, whenever the effective corporate tax rate remains below 15%, the difference is charged as a top-up tax.
Qualified Domestic Minimum Top-up Tax (QDMTT)
In this context, the OECD's BEPS Pillar Two rules have entered into force in Turkey. On 3 October 2025, the Revenue Administration released the draft "General Communiqué on the Implementation of the Local and Global Minimum Top-Up Corporate Tax" for public consultation and the draft is continued. The communiqué is final form in the coming period. In conclusion, the submit and payment deadlines for the Qualified Domestic Minimum Top-Up Tax (QDMTT) returns for the 2024 fiscal year have been extended until the end of 15 January 2026.
Regarding the Qualified Domestic Top-Up Tax (QDMTT), if a subsidiary of the ultimate parent entity, resident in a country that has adopted the Pillar II rules, has an effective tax rate (ETR) below 15% based on consolidated financial statement data, the difference must be reported and paid to the local tax authorities as Top-Up Tax. However, if the Safe Harbour tests under Pillar II rules are provide, the QDMTT can be calculated as zero. When QDMTT is paid to local authorities, the ultimate parent entity can offset these taxes when calculating the Global Minimum Top-Up Corporate Tax.
Additionally, on 2 December 2025, the Revenue Administration announced that, it explained the “Qualified Domestic Minimum Top-Up Tax (QDMTT)" available for use in the e-Declaration Test environment to enable taxpayers covered by the scope to experience the data entry and calculation processes.
If the consolidated revenue of the relevant multinational group exceeds the threshold amounts, it may be necessary to establish QDMTT liability in Turkey. In this context, based on the GloBE calculations to be made by the ultimate parent entity, if a QDMTT return is filed and calculated for the relevant period, the additional tax (top-up tax) must be paid by 15 January 2026 at the latest. Furthermore, even if no top-up tax is calculated or the safe harbour conditions are met, the notification and declaration obligation continues, as stipulated in the legislation. These explanations are for general information purposes only and the relevant taxpayer must assess the obligations relating to implementation by taking into account their own group data and final calculations.
Kind regards,
“Our explanations given above contain general information on the subject. No liability claims can be made against Rödl Türkiye for the consequences arising from or related to the content of this document."
