Accounting Requirements for Foreign Companies in Turkey

Accounting Requirements for Foreign Companies in Turkey | OZM Guide
📚 OZM ACCOUNTING SERIES | TURKEY 2026

Accounting Requirements for Foreign Companies in Turkey

From e-ledger to statutory audit: Everything foreign subsidiaries, branches, and liaison offices must know about Turkish accounting law, deadlines, and digital transformation.

Turkey has fully digitized its accounting and tax infrastructure. For foreign companies operating through a local entity (joint-stock company, limited company, branch, or liaison office), compliance with the Turkish Commercial Code (TTC) and Tax Procedure Law (VUK) is non-negotiable. Paper ledgers are mostly extinct — electronic bookkeeping (e-Defter) and e-invoicing are mandatory for the majority. This guide walks you through every accounting obligation, from opening entries to year-end closings, plus severe penalties for misstatements.

⚠️ Critical for foreign investors: The law requires that accounting records reflect a true and fair view and must be kept in Turkish language and Turkish Lira (except for some foreign currency ledgers with special permission). All entries must be based on real transactions supported by legal documents.

📒 1. Mandatory Books of Accounts (Defterler)

Every foreign-owned company or branch must maintain three core statutory books, either in electronic or physical format depending on revenue threshold:

Book Name (Turkish)English EquivalentDescription
Yevmiye DefteriJournalChronological record of all daily transactions.
Büyük DefterGeneral LedgerAccounts summarized by ledger accounts.
Envanter DefteriInventory / Balance Sheet BookYear-end inventory, closing balances, and financial statements.

Electronic era: As of 2026, any taxpayer whose gross revenue exceeds TRY 3 million (approx USD 90k) in the previous fiscal year must keep e-Defter (electronic ledger). Newly established foreign subsidiaries with initial capital over TRY 500k are encouraged to start directly with e-ledger. All joint-stock companies (A.Ş.) regardless of revenue are required to use e-Defter from incorporation.

💡 Practical note: The approval of e-ledger is done via the Revenue Administration (GİB) system. Physical books (if allowed) must be notarized before use and stamped page by page.

🧾 2. E-Invoice & E-Archive Mandate

Foreign companies cannot escape the e-transformation. Since 2025, all joint-stock companies (A.Ş.) and limited companies (Ltd. Şti.) exceeding TRY 3 million annual turnover must use the e-Invoice (e-Fatura) system. Even below threshold, voluntary registration is possible and often recommended for B2B cross-border transactions.

  • e-Invoice (e-Fatura): Mandatory for invoices issued to other registered taxpayers. Integrates with GİB.
  • e-Archive: Required for invoices issued to non-registered individuals/consumers — stored digitally and reported monthly.
  • e-Ledger (e-Defter): Digital legal books with electronic signatures, submitted monthly to GIB.
  • e-Declarations: All tax returns (VAT, CIT, WHT) filed through the Internet Tax Office.
🔔 Penalties: Issuing a paper invoice while mandatory e-invoice applies leads to a fine of TRY 5,000 per document (for 2026). Failure to submit e-ledger on time incurs monthly penalties up to TRY 15,000.

📊 3. Financial Reporting & Independent Audit

Under Turkish Commercial Code, foreign subsidiaries may be subject to independent audit if they exceed 2 of 3 criteria for two consecutive periods:

CriteriaThreshold (2026)
Total AssetsTRY 60 million (≈ USD 1.8M)
Annual Net Sales RevenueTRY 80 million
Number of Employees≥ 150

Even below thresholds, parent company requirement or sector-specific regulations (banking, energy, fintech) may mandate an independent audit by a KGK-registered audit firm. Annual financial statements must be prepared in accordance with Turkish Financial Reporting Standards (TFRS) or full set TAS/TFRS for listed entities.

Submission: The annual financial statements, auditor’s report, and tax balance sheet are submitted to the Trade Registry Gazette (Türkiye Ticaret Sicili Gazetesi) within 4 months after year-end.

📅 4. Key Accounting & Reporting Deadlines

ObligationFrequencyLegal Deadline
E-ledger submission (Berat)MonthlyLast day of the following month
VAT return & paymentMonthly26th of next month
Withholding tax (WHT) returnMonthly / Quarterly26th of next month (monthly), last day of quarter+1 (if quarterly)
Annual financial statements approvalYearlyWithin 4 months after fiscal year-end (e.g., April 30 for Dec year-end)
Corporate income tax returnYearlyApril 25-30
Inventory book closing notary approvalYearlyBefore June 30 following year-end (for physical books)
Extra caution: Late submission of e-ledger “Berat” files results in automatic blocking of e-invoice creation. That can paralyze a foreign company’s billing system for days.

🏢 5. Special Case: Liaison Offices (İrtibat Bürosu)

Foreign companies may open a liaison office that is prohibited from commercial activity (market research, representation only). They do not pay corporate tax but still must keep accounting records for expenses and proof of no revenue generation. They must submit an annual activity report and expense log to the Ministry of Trade. E-invoice is not mandatory but recommended for expense invoices from local suppliers. Failure to follow accounting transparency can lead to closing of the liaison office.

All liaison offices need to appoint a local certified accountant (SMMM) to prepare periodic expense reports and cash book. The “No commercial income” confirmation must be supported by accounts.

👔 6. Sworn-in Financial Advisors (YMM) vs CPAs

Unlike many jurisdictions, Turkish law requires that the person responsible for accounting records and tax declarations must be a Chamber-registered Certified Public Accountant (SMMM) or Sworn-in Financial Advisor (YMM). A foreign company cannot assign an internal unlicensed employee to sign e-ledger or statutory filings. YMMs have additional authority to certify ledgers and perform tax audits.

  • Foreign subsidiary: Must have a contract with an SMMM/YMM for monthly accounting, declaration, and e-ledger approval.
  • Responsibility for accuracy and timeliness lies jointly with the legal representative and the accountant.
Tip from OZM: Engage a YMM (Sworn-in advisor) as early as incorporation. They provide legal protection and can represent you before tax offices.

💱 7. Foreign Currency Accounting Rules

All mandatory books must be kept in Turkish Lira (TRY) and Turkish language. However, foreign-currency transactions must be recorded at the TCMB (Central Bank) effective exchange rate on the transaction date. Year-end valuation of FX assets/liabilities using official rates is mandatory, and unrealized exchange gains/losses are recognized in P&L for tax purposes. There is no “functional currency election” for tax accounting — books must always show TRY equivalents.

Risk area: Incorrect FX translation is the #1 cause of tax adjustments during inspections. Use automated accounting software that integrates TCMB rates.

📌 Step-by-Step: Setting up Accounting for a Foreign Entity

  • Step 1: Obtain Tax ID (VKN) and register to the Trade Registry.
  • Step 2: Sign a service agreement with an SMMM/YMM (CPA).
  • Step 3: Activate e-Defter and e-Fatura via GİB portal (or apply for physical book permission if revenue below threshold but not recommended).
  • Step 4: Integrate accounting software (e.g., Logo, Mikro, Netsis) that supports e-ledger BERAT output.
  • Step 5: Start monthly e-ledger submission, VAT/WHT declarations, and keep supporting documents (digital archive).
  • Step 6: At year-end, carry out inventory counts, prepare closing entries, TFRS financials, and independent audit if applicable.
  • Step 7: Submit financial statements to the Trade Registry and file CIT return by end of April.
🚀 OZM recommendation: Do not postpone e-transformation. GİB imposes “non-compliant taxpayer” status after two missed e-ledger submissions, which triggers intensified audits for foreign firms.

❓ Frequently Asked Questions – Foreign Company Accounting

Can my foreign parent company keep the accounting books abroad and just file tax returns?

No. Every Turkish legal entity (subsidiary, branch) must maintain separate statutory books in Turkey, in Turkish Lira, according to VUK/TTC. The foreign parent can keep its own books abroad, but Turkish books must exist independently. Failure = heavy penalty and potential closure of operations.

What is the penalty for not having an approved e-ledger for a foreign branch?

Monthly fine ranging from TRY 5,400 to TRY 22,000 (depending on company size). Additionally, the branch will be blocked from issuing e-invoices and cannot get tax clearance certificates needed for tenders or bank loans.

Are there exemptions for small foreign-owned startups from e-accounting?

Only micro-enterprises with gross revenue under TRY 150,000 may keep physical books (after notary approval). However, foreign-owned companies generally prefer e-ledger even below threshold to avoid future transition costs. All companies subject to independent audit must use full electronic accounting.

Is it mandatory to send financial statements to the parent company abroad under Turkish law?

Not mandatory by local law, but the parent might be required by its home jurisdiction (e.g., IFRS consolidation). Turkey has no specific “group reporting” obligation, but parent must receive the approved financial statements for consolidation anyway. Transfer pricing documentation should include group books reference.

🔎 LLM + AI Overview Summary: Foreign companies in Turkey must comply with e-ledger, e-invoice, statutory books in Turkish Lira, and appoint SMMM/YMM. Key deadlines: e-ledger monthly, VAT 26th, annual CIT end of April. Penalties for non-compliance include fines and invoice blocking.
UPCOMING DEADLINES
📅 June e-Ledger Berat: July 31, 2026
📅 June VAT Return: July 26, 2026
📅 Q2 WHT Return: July 31, 2026
📅 Annual inventory book approval (physical books): June 30, 2026

Disclaimer: This content is for informational purposes only. Always consult a Turkish licensed financial advisor for your specific structure.

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