Global Minimum Tax in Turkey (Pillar Two): What Multinationals Must File in 2026

Reviewed by Evren Özmen, CPA (SMMM)
Turkish Certified Public Accountant · Licensed by TÜRMOB, Reg. No. 35675 · Last reviewed September 2026






Global Minimum Tax in Turkey (Pillar Two): 2026 Guide


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.

15%
Minimum effective tax rate
€750m
Group revenue threshold (2 of 4 yrs)
FY2024
First year in scope (IIR & QDMTT)
31 Jul 2026
Extended first-year filing deadline

Last reviewed: September 2026 · Based on Turkish legislation and official guidance.

Quick answer: Turkey applies the OECD Pillar Two global minimum tax under Law No. 7524. Multinational groups with consolidated revenue above EUR 750 million in at least two of the last four years must ensure a 15% minimum effective tax rate on their Turkish profits. A Turkish group entity generally files a local minimum top-up tax return (QDMTT) and a notification, and where Turkey is the filing jurisdiction, a global minimum top-up tax return with a GloBE-equivalent information return. The obligation to file continues even when a safe harbour reduces the tax to zero. For the first year (FY2024, calendar-year groups), the global return deadline was extended to 31 July 2026.

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?

Pillar Two is the OECD framework that ensures large multinational groups pay at least a 15% effective tax rate in every country where they operate. Where a group’s effective rate in a country falls below 15%, a top-up tax brings it up to that floor. Turkey implemented these rules through Law No. 7524, creating both a local top-up tax on Turkish profits and the global rules that can pull in a Turkish parent.

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?

The Turkish Pillar Two rules apply to constituent entities of multinational groups whose consolidated financial-statement revenue exceeds EUR 750 million in at least two of the four fiscal years preceding the tested year. Below that threshold, a group is outside Pillar Two, although it may still be subject to Turkey’s separate domestic minimum corporate tax and ordinary corporate tax.

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

Turkey implemented all three Pillar Two charging mechanisms. The Income Inclusion Rule (IIR) and the local Qualified Domestic Minimum Top-up Tax (QDMTT) apply from fiscal year 2024; the Undertaxed Profits Rule (UTPR) applies from fiscal year 2025. In practice, the QDMTT means Turkey collects any top-up tax on low-taxed Turkish profits itself, rather than leaving it to a foreign parent jurisdiction.
Turkish Pillar Two mechanisms and effective years
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

These are two separate regimes that are easy to confuse. Pillar Two is the 15% global minimum tax for groups above EUR 750 million. Turkey’s domestic minimum corporate tax is a different rule, effective from 2025, under which a company’s corporate tax cannot be less than 10% of its corporate income before certain deductions. A Turkish company can be subject to one, both, or neither.
Two different Turkish minimum taxes
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

A Turkish constituent entity in scope generally files a notification form and a local minimum top-up tax return under liability code 0063. Where Turkey is the jurisdiction that reports the global top-up tax, it also files a global minimum top-up tax return under liability code 0064, together with a GloBE-equivalent information return submitted as an annex to that global return.
Turkish Pillar Two filing components
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

The GloBE-equivalent information return and the global top-up tax return are generally due within 15 months after the fiscal year-end, extended to 18 months for the first (transitional) year. For calendar-year groups, the FY2024 global return and payment were originally due on 30 June 2026 and were extended to 31 July 2026 by a Turkish Revenue Administration notice. Later years revert to the 15-month timetable.
Illustrative Turkish Pillar Two deadlines (calendar-year groups)
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

The transitional CbCR safe harbour can reduce a jurisdiction’s top-up tax to zero when a simple test based on country-by-country reporting data is met — typically a de minimis test, a simplified effective-tax-rate test, or a routine-profits test. Meeting a safe harbour removes the tax, but it does not remove the obligation to file the Turkish return and notification and to document that the test was satisfied.

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.

Practical note

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

There is no single fee for Turkish Pillar Two compliance. The cost depends on how many filings are required (notification only, local return, or the full global return), whether a safe harbour applies or a full GloBE calculation is needed, the number of Turkish constituent entities, the quality of the parent’s data package, and currency conversion into Turkish lira.
  • 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

  1. Confirm scope. Test the EUR 750 million threshold over the group’s last four years.
  2. Map the Turkish entities. Identify every Turkish constituent entity and joint venture in the group.
  3. Confirm the filing route. Determine whether Turkey files only a notification and local return, or also the global return and GloBE-equivalent information return.
  4. Obtain the group determination. Secure the parent’s safe-harbour test result and qualified country-by-country data for Turkey.
  5. Register. Establish the relevant liability (0063 for the local top-up tax; 0064 where the global return is filed in Turkey).
  6. Prepare and file. Complete the notification and returns, applying the safe harbour or the full calculation, converting figures to Turkish lira.
  7. 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.

Example 1 — Safe harbour met, tax zero, filing still required
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.
Example 2 — Low Turkish ETR, top-up tax due
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.
Example 3 — Below the threshold
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.

Disclaimer. This article is provided for general informational purposes and does not constitute legal, tax, accounting, or investment advice. Turkish tax treatment depends on the group’s structure, consolidated results, safe-harbour position, documentation, and specific facts. Professional advice should be obtained before taking action.
EO
Evren Ozmen, CPA (SMMM)
Turkish Certified Public Accountant · Licensed by TURMOB, Reg. No. 35675 · Advising multinational groups and foreign investors on Turkish corporate tax, Pillar Two, accounting, and compliance at OZM Consultancy. Reviewed September 2026.

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.



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Evren Özmen, CPA (SMMM)

Turkish Certified Public Accountant (SMMM), licensed by TÜRMOB — Reg. No. 35675. Advising international investors and companies on Turkish tax, accounting and compliance at OZM Consultancy, Istanbul.