Systems CPA · Turkey Tax Guides for Foreign Companies
Global Minimum Tax in Turkey (Pillar Two): What Multinationals Must File in 2026
Turkey has adopted the OECD Pillar Two 15% global minimum tax. Large multinational groups with a Turkish entity now face local and global top-up tax returns — and a filing obligation that continues even when the tax is zero. Here is who is in scope, what to file, and the 31 July 2026 deadline.
Last reviewed: September 2026 · Based on Turkish legislation and official guidance.
Key facts at a glance
| Regime | Local and Global Minimum Complementary Corporate Tax (Pillar Two / GloBE) |
|---|---|
| Legal basis | Law No. 7524 (Official Gazette, 2 August 2024, No. 32620), amending the Corporate Tax Law |
| Minimum rate | 15% effective tax rate (ETR) on GloBE income |
| Scope threshold | Consolidated group revenue > EUR 750 million in at least 2 of the last 4 fiscal years |
| Effective years | IIR and QDMTT (local top-up) from FY 2024; UTPR from FY 2025 |
| Turkish filings | Notification form; local minimum top-up tax return (0063); global minimum top-up tax return (0064) with GloBE-equivalent information return where applicable |
| First deadline | FY2024 global return and payment extended to 31 July 2026 (calendar-year groups) |
| Zero tax? | A safe harbour can reduce top-up tax to zero, but the return must still be filed |
Key takeaways
- Turkey has enacted the Pillar Two 15% global minimum tax for large multinational groups under Law No. 7524.
- Scope is set by group size: EUR 750 million consolidated revenue in at least two of the last four years.
- Turkey introduced both a local top-up tax (QDMTT) and the global rules (IIR from 2024, UTPR from 2025).
- This is different from Turkey’s domestic 10% minimum corporate tax, which is a separate 2025 rule for all corporations.
- Even where a safe harbour brings the top-up tax to zero, the Turkish return and notification still have to be filed.
- For FY2024, the first global return and payment deadline was extended to 31 July 2026.
What Is the Pillar Two Global Minimum Tax?
Under the OECD GloBE (Global Anti-Base Erosion) rules, a multinational group calculates its effective tax rate jurisdiction by jurisdiction. If the rate in a jurisdiction is below 15%, the difference is collected as a top-up tax. Turkey adopted this system in its Corporate Tax Law, using the terms local and global minimum complementary corporate tax. The result is that a foreign group with a Turkish subsidiary, and a Turkish group expanding abroad, both now sit inside a new, data-heavy compliance regime that is separate from ordinary corporate tax.
Who Is in Scope in Turkey?
Scope depends on the group, not the single Turkish entity. A small Turkish subsidiary is in scope if its worldwide group meets the EUR 750 million test. Purely domestic Turkish groups without foreign operations are generally outside the global rules but can still fall within the local top-up tax where it applies. The test looks back over the group’s consolidated accounts, so a group that crossed the threshold in two of the last four years remains in scope even if a single recent year was lower.
The Three Mechanisms: IIR, QDMTT and UTPR
| Mechanism | What it does | Effective from |
|---|---|---|
| Local top-up tax (QDMTT) | Turkey itself collects top-up tax on low-taxed Turkish profits | FY 2024 |
| Income Inclusion Rule (IIR) | A Turkish parent pays top-up tax on low-taxed foreign subsidiaries | FY 2024 |
| Undertaxed Profits Rule (UTPR) | Backstop that allocates top-up tax where the IIR does not apply | FY 2025 |
The QDMTT is the mechanism most Turkish subsidiaries encounter first. Because Turkey collects its own top-up tax, a foreign parent’s IIR generally gives credit for the Turkish QDMTT already paid, keeping the revenue in Turkey rather than exporting it to the parent country.
Pillar Two vs. Turkey’s Domestic 10% Minimum Corporate Tax
| Feature | Pillar Two (15% global minimum) | Domestic minimum corporate tax (10%) |
|---|---|---|
| Who it targets | MNE groups above EUR 750 million | Turkish corporations generally, regardless of size |
| Rate | 15% effective tax rate (GloBE) | 10% of corporate income before certain deductions |
| Basis | GloBE income, jurisdiction by jurisdiction | Turkish taxable income (parallel calculation) |
| Effective | FY 2024 (UTPR FY 2025) | FY 2025 |
| Nature | OECD Pillar Two / GloBE regime | Domestic corporate tax floor, not Pillar Two |
The standard Turkish corporate income tax rate is 25% (30% for financial-sector companies), so many companies never reach either floor. The floors matter where incentives, exemptions, or losses push the effective rate down — for example technology-development-zone benefits or participation exemptions. Treating the two minimum taxes as one is a frequent and costly error.
What a Turkish Group Entity Has to File
| Filing | Turkish liability code | Who files it |
|---|---|---|
| Notification form (global minimum tax) | — | In-scope Turkish entities that are not filing the global return themselves |
| Local minimum top-up tax return (QDMTT) | 0063 | Turkish constituent entities with a local top-up position |
| Global minimum top-up tax return | 0064 | Filed where Turkey is the reporting jurisdiction for the global top-up tax |
| GloBE-equivalent information return | — | Filed as an annex to the global return where required |
In many foreign-parent structures, the Turkish subsidiary does not file the full global return or the complete GloBE information return — the parent files those in its own jurisdiction. The Turkish entity then typically deals with the notification and the local top-up tax return, applying the safe-harbour determination made at group level. Confirming which of these applies is the first step of any Turkish Pillar Two engagement.
Deadlines and the 31 July 2026 Extension
| Fiscal year | Standard rule | Deadline |
|---|---|---|
| FY 2024 (first year) | 18 months after year-end | 30 June 2026, extended to 31 July 2026 |
| FY 2025 | 15 months after year-end | Around 31 March 2027 |
The extension applies to the global minimum top-up tax return and its payment, and the GloBE-equivalent information return that is filed as an annex to it. Groups with a non-calendar fiscal year should calculate their own dates from the 15-month and 18-month rules and confirm the current position, as deadlines in this new regime have already been adjusted once.
Safe Harbours: Zero Tax Still Means a Filing
This is the single most misunderstood point in practice. Many groups assume that if the safe harbour applies and no tax is due, nothing needs to be filed in Turkey. That is incorrect: the local top-up tax return and the notification are still required, and the safe-harbour outcome has to be applied and evidenced inside the return. The safe-harbour determination itself is normally made at group level by the parent, using qualified country-by-country reporting data, and then applied in the Turkish filing.
In a typical foreign-parent structure, the Turkish adviser does not recompute the group’s GloBE effective tax rate or the safe-harbour test from scratch. Instead, the Turkish entity applies the group’s determination in the local return — which means the quality and timeliness of the parent’s data package drives the whole Turkish filing.
Compliance Cost Drivers
- Which filings apply — a notification plus a safe-harbour local return is far lighter than a full global return with a complete GloBE information return.
- Safe harbour vs. full calculation — applying a transitional CbCR safe harbour is much less work than a full jurisdictional ETR and top-up computation.
- Number of Turkish constituent entities — each in-scope entity adds registration and filing work.
- Parent data package — a clean, timely safe-harbour determination and qualified CbCR data from the parent reduces Turkish-side effort; missing data increases it.
- Currency conversion — group figures reported in another currency must be converted to Turkish lira on the agreed basis.
Step-by-Step: Getting the Turkish Filing Right
- Confirm scope. Test the EUR 750 million threshold over the group’s last four years.
- Map the Turkish entities. Identify every Turkish constituent entity and joint venture in the group.
- Confirm the filing route. Determine whether Turkey files only a notification and local return, or also the global return and GloBE-equivalent information return.
- Obtain the group determination. Secure the parent’s safe-harbour test result and qualified country-by-country data for Turkey.
- Register. Establish the relevant liability (0063 for the local top-up tax; 0064 where the global return is filed in Turkey).
- Prepare and file. Complete the notification and returns, applying the safe harbour or the full calculation, converting figures to Turkish lira.
- Document and diarise. Keep the supporting data and calendar the following year’s 15-month deadline.
Worked Examples
The following anonymized examples are simplified and do not guarantee the same outcome for any specific group.
- Profile
- A foreign group above EUR 750 million with one Turkish manufacturing subsidiary; the parent’s transitional CbCR safe harbour is met for Turkey.
- Issue
- No top-up tax is due, but the Turkish obligations remain.
- Likely treatment
- File the notification and the local top-up tax return (0063), applying the group’s safe-harbour result; no full global return or GloBE information return prepared in Turkey.
- Main risk
- Assuming zero tax means nothing to file, and missing the return and notification.
- Profile
- An in-scope group whose Turkish entity benefits from incentives that push its effective rate below 15%; the safe harbour is not met.
- Issue
- A local top-up tax arises to bring the Turkish effective rate up to 15%.
- Likely treatment
- Compute and pay the QDMTT via the local return (0063); the parent’s IIR generally credits the Turkish tax already paid.
- Main risk
- Overlooking how Turkish incentives interact with the GloBE effective-tax-rate calculation.
- Profile
- A group with consolidated revenue of EUR 300 million and a Turkish subsidiary.
- Issue
- The group is below EUR 750 million, so Pillar Two does not apply.
- Likely treatment
- No Pillar Two filing. The Turkish company still applies ordinary corporate tax and the separate domestic 10% minimum corporate tax where relevant.
- Main risk
- Confusing the two regimes and either over-filing for Pillar Two or ignoring the domestic minimum.
Common Mistakes
- Confusing the 15% Pillar Two tax with the 10% domestic minimum corporate tax. They are separate regimes with different scope.
- Assuming a safe harbour removes the filing. Zero tax still requires the return and notification.
- Testing scope on the Turkish entity alone. The EUR 750 million test is at group level.
- Missing the notification. In-scope entities not filing the global return still have to notify.
- Underestimating data dependency. The Turkish filing relies on the parent’s safe-harbour result and qualified CbCR data.
- Missing the first-year deadline. The FY2024 global return runs to 31 July 2026 for calendar-year groups, not the ordinary corporate tax date.
Talk to a licensed Turkish CPA about your Pillar Two filing
Turkish Pillar Two compliance turns on which filings your group must make, whether a safe harbour applies, and how the parent’s data flows into the Turkish return. Systems CPA helps foreign groups and their Turkish subsidiaries confirm scope, establish the 0063 and 0064 liabilities, and prepare the notification, local and global returns. We reply in English, usually within one business day.
Frequently Asked Questions
Does Turkey have the Pillar Two global minimum tax?
Yes. Turkey adopted the OECD Pillar Two rules through Law No. 7524 (Official Gazette, 2 August 2024), adding a local and global minimum complementary corporate tax to the Corporate Tax Law. The rules impose a 15% minimum effective tax rate on multinational groups with consolidated revenue above EUR 750 million in at least two of the last four fiscal years, with the income inclusion rule and local top-up tax effective from fiscal year 2024.
What is the deadline for the first Turkish Pillar Two return?
For calendar-year groups, the FY2024 global minimum top-up tax return and payment were originally due on 30 June 2026 (18 months after year-end) and were extended to 31 July 2026 by a Turkish Revenue Administration notice. The GloBE-equivalent information return, filed as an annex to the global return, is covered by the same extension. From FY2025, the standard 15-month deadline applies.
Do we still have to file if a safe harbour makes the tax zero?
Yes. Meeting the transitional country-by-country reporting safe harbour can reduce the Turkish top-up tax to zero, but it does not remove the filing obligation. The local minimum top-up tax return and the notification must still be filed, and the safe-harbour outcome has to be applied and documented within the return.
What are the 0063 and 0064 liability codes?
In the Turkish system, 0063 is the liability for the local minimum top-up tax return (the domestic QDMTT), and 0064 is the liability for the global minimum top-up tax return. A Turkish entity establishes 0063 where it has a local top-up position, and 0064 only where Turkey is the jurisdiction filing the global top-up tax return.
How is Pillar Two different from Turkey’s 10% domestic minimum corporate tax?
They are separate. Pillar Two is the 15% global minimum tax for groups above EUR 750 million, based on GloBE income. The domestic minimum corporate tax, effective from 2025, is a Turkish rule under which corporate tax cannot be less than 10% of corporate income before certain deductions, and it can apply to companies of any size. A company may face one, both, or neither.
Who is in scope in Turkey?
Constituent entities of multinational groups whose consolidated financial-statement revenue exceeds EUR 750 million in at least two of the four preceding fiscal years. Scope is tested at group level, so even a small Turkish subsidiary is in scope if its worldwide group meets the threshold. Groups below the threshold are outside Pillar Two.
Conclusion
Turkey’s adoption of Pillar Two means that, for large multinational groups, having a Turkish entity now carries a distinct annual compliance cycle on top of ordinary corporate tax. The practical work is less about paying tax — in many cases a safe harbour brings the Turkish top-up tax to zero — and more about filing correctly and on time, applying the group’s determination in the right return, and keeping the 0063 and 0064 liabilities and the notification in order. With the first-year deadline set at 31 July 2026 for calendar-year groups, the immediate priority for most groups is confirming scope, the filing route, and the safe-harbour position for FY2024.
Sources and Legal References
- Law No. 7524 introducing the local and global minimum complementary corporate tax — Official Gazette, 2 August 2024, No. 32620, resmigazete.gov.tr.
- Corporate Tax Law provisions on minimum complementary corporate tax — Turkish legislation, mevzuat.gov.tr.
- General Communique and filing guidance on local and global minimum top-up corporation tax, and the FY2024 filing extension to 31 July 2026 — Turkish Revenue Administration, gib.gov.tr.
Turn Turkey compliance into certainty
SYSTEMS CPA supports foreign-owned companies with company formation, accounting, tax compliance and payroll in Turkey — one accountable local partner. Reviewed by Evren Özmen, SMMM (Certified Public Accountant), TÜRMOB Reg. No. 35675.
