Is Turkey Reported Separately Under EU Public CbCR? Grey List Impact for 2026

By Evren Özmen, CPA (TÜRMOB Reg. No. 35675) · SYSTEMS CPA, Istanbul · Published 22 October 2026 · Updated 22 October 2026

Key facts at a glance

What is EU public CbCR?

Unlike the OECD country-by-country report that groups already file with tax authorities, the EU report is public. Investors, customers, journalists, NGOs, trade unions and competitors can read it. That is the whole design: transparency by publication, not by exchange between administrations.

The reporting window is the financial year starting on or after 22 June 2024. Most Member States transposed the Directive on that baseline; a few moved earlier (Romania from FY2023). For a group with a calendar financial year, FY2025 is the first year, and its report must be public within 12 months of the balance sheet date — that is, by 31 December 2026.

Why does Turkey’s grey list status matter for public CbCR?

For all other non-EU countries, a group may publish one aggregated “other tax jurisdictions” figure. In practice, that means a Turkish subsidiary’s numbers would normally disappear into a large rest-of-world total next to the UK, the US or the UAE. The grey list removes that option for Turkey.

The 9 October 2026 update did not change Turkey’s position. The Council recorded that Turkey is still not fully in line with its commitment on automatic exchange of information with all Member States — the long-running issue is the absence of exchange with Cyprus. Unless that is resolved and the Council removes Turkey at a future review (the next is scheduled for February 2027), the separate-disclosure rule keeps applying year after year.

The detail most groups miss: no deferral for Turkey

Member States may allow a group to omit commercially sensitive data for up to five years, provided the omission is disclosed and the data is published later. That safeguard does not apply to information on Annex I and qualifying Annex II jurisdictions. So the one country where a group might most want to use the deferral — because it is reported on its own — is exactly where the deferral is unavailable.

What exactly must be published for Turkey?

Under Article 48c of the Accounting Directive, the report must show, for Turkey as for each EU Member State:

The report must also name the ultimate parent, list the subsidiaries in the EU and in listed jurisdictions, and give a narrative explanation of material discrepancies between tax accrued and tax paid. Groups may instead build the report on the OECD CbCR data definitions (Article 48c(4)), which is usually the efficient route because the data already exists.

The statutory auditor of the reporting EU entity must state in its audit report whether the entity was required to publish a public CbCR report and, if so, whether it did (Article 48f). Non-publication is therefore visible in the audited accounts, not only to the regulator.

Public CbCR vs OECD CbCR: what is different?

Public CbCR vs Pillar Two: why the numbers must agree

Turkey adopted the OECD global minimum tax through Law No. 7524 (Official Gazette, 2 August 2024), including a domestic minimum top-up tax. Many groups rely on the transitional CbCR safe harbour, which uses qualified CbCR data to test whether Turkey’s effective tax rate clears 15%. The same group will now publish Turkish profit and tax figures in the public report.

A Turkish ETR that looks low in the public report but passes the safe harbour in the Pillar Two filing — or the reverse — is exactly the kind of inconsistency a tax inspector, an auditor or a journalist will ask about. Our guide to the global minimum tax in Turkey covers the Pillar Two filings; the point here is that the two data sets now need one reconciliation.

Turkish parent vs EU parent: who actually files?

Turkish-parented groups with EU subsidiaries

There is a practical way out of multiple filings: if the Turkish parent itself publishes a report that meets the Directive’s content and timing rules on its website, and the EU subsidiaries reference it, the subsidiaries are generally relieved of separate preparation. Member State rules differ on the exact mechanics, so the conditions must be checked country by country.

EU-parented groups with Turkish subsidiaries

An EU parent above the threshold publishes the report itself. Its Turkish subsidiary does not file anything in Turkey under the Directive, but the Turkish figures — revenue, headcount, profit, tax accrued and paid — become public on the parent’s report. For Turkish management teams, the practical question is whether the local numbers tell a coherent story when read in isolation.

How Turkey compares with other non-EU jurisdictions

Groups active in Turkey usually also operate in the UK, Switzerland, the UAE or North Africa. Their treatment in the public report is not the same:

The comparison matters for group communication: a Dubai or London entity can sit inside an aggregated figure, while the Istanbul entity next to it is published line by line.

Worked case analyses

The scenarios below are anonymised composites based on the types of files we review. Figures are rounded and illustrative.

What happens if…?

What should companies do before 31 December 2026?

1. Confirm scope. Test consolidated revenue for the last two years; map every EU subsidiary against the medium/large thresholds and every EU branch against the EUR 12 million test, by Member State.
2. Decide who publishes. Parent-level publication or subsidiary-level filing; confirm the business-register and website requirements in each relevant Member State.
3. Build the Turkey line separately. Aggregate all Turkish group entities (and Turkish branches) into one jurisdictional figure, using consistent definitions for revenue, current tax and cash tax.
4. Reconcile. Compare the public figures with the Turkish CbC report, consolidated accounts, Turkish corporate tax returns and Pillar Two filings; document every material difference.
5. Stress-test the transfer pricing story. Check that published Turkish revenue, headcount, profit and tax are consistent with the functional profile, royalty, service and financing arrangements in the group’s transfer pricing documentation.
6. Prepare the format. Apply the common template and XHTML / Inline XBRL requirements under Implementing Regulation (EU) 2024/2952, plus any translation into an EU official language.
7. Write the narrative. Explain the accrued-versus-paid gap and any incentive or exemption regime affecting the Turkish effective rate.

What drives the scope and effort of a public CbCR review?

We do not publish fees; engagements are scoped privately. The effort depends mainly on:

• the number of Turkish group entities and branches that need to be combined into one Turkey figure;
• how many EU Member States are involved, since transposition rules differ;
• whether OECD CbCR data already exists in a reusable, reconciled form;
• the complexity of Turkish incentives, exemptions and inflation-related adjustments affecting tax accrued;
• whether a transfer pricing narrative and reconciliation to Pillar Two filings is required;
• electronic format (iXBRL) and translation needs.

Our assessment

Turkey’s continued presence on the EU grey list turns public CbCR from an EU-only compliance task into a Turkey-specific disclosure. For in-scope groups, the Turkish financial and tax position will be published on its own line, cannot be deferred, and will be compared with every other country in the report. The question is no longer whether Turkish data will be visible, but whether it will be accurate, consistent and explainable — to tax authorities, auditors, investors, customers and the press.

Primary sources

• Directive (EU) 2021/2101 — disclosure of income tax information (EUR-Lex)
• Commission Implementing Regulation (EU) 2024/2952 — common template and electronic formats (EUR-Lex)
• EU list of non-cooperative jurisdictions for tax purposes — Council of the EU
• Economic and Financial Affairs Council, 9 October 2026
• European Commission — Council updates the EU list (9 October 2026)
• Corporate Tax Law No. 5520 (Kurumlar Vergisi Kanunu) — mevzuat.gov.tr
• Revenue Administration (GİB) — Transfer Pricing General Communiqué No. 1 and No. 5
• Official Gazette (Resmî Gazete) — Law No. 7524 (2 August 2024) and Presidential Decision No. 8956

Prefer SYSTEMS CPA in your Google results: add systemscpa.com as a preferred source.

This article is general information as of 22 October 2026 and is not tax advice for a specific group. Member State transposition rules differ; confirm the position for each relevant jurisdiction before filing.