Turkey Pillar Two & QDMTT Compliance for Multinational Groups
Türkiye has implemented the OECD Pillar Two global minimum tax framework for large multinational groups. For an in-scope Turkish subsidiary, the practical challenge is no longer only whether Pillar Two applies. The finance team must identify the Turkish filing role, produce GloBE-quality data, calculate or support the local QDMTT position, document safe-harbour eligibility and coordinate with the group tax team before local deadlines.
Türkiye’s Pillar Two rules generally apply to constituent entities of multinational enterprise groups whose consolidated revenue reaches the Turkish-lira equivalent of EUR 750 million in at least two of the four fiscal years preceding the tested year. Türkiye applies a 15% minimum-tax framework through a domestic minimum top-up tax (QDMTT), the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR). The QDMTT and IIR apply for fiscal years beginning on or after 1 January 2024; UTPR applies for fiscal years beginning on or after 1 January 2025. Local Turkish reporting, notification and payment responsibilities depend on the group structure, filing entity, safe harbours and information-exchange position.
Who Is in Scope of Pillar Two in Turkey?
Türkiye’s domestic legislation follows the core Pillar Two revenue threshold. The rules apply to multinational enterprise groups that meet the consolidated-revenue test based on the ultimate parent entity’s consolidated financial statements.
The general test is:
- The group is multinational rather than purely domestic.
- Annual consolidated revenue reaches the Turkish-lira equivalent of EUR 750 million.
- The threshold is met in at least two of the four fiscal years immediately preceding the tested fiscal year.
The detailed rules contain exclusions for specified entities and special rules for matters such as short fiscal years, joint ventures and group restructurings. Scope should therefore be tested at group level rather than by looking only at the Turkish subsidiary’s own revenue.
Turkey Pillar Two: QDMTT, IIR and UTPR
| Rule | What it does | Turkish effective date |
|---|---|---|
| QDMTT / Local Minimum Top-up Tax | Allows Türkiye to collect top-up tax on low-taxed GloBE income arising in Türkiye before another jurisdiction applies IIR or UTPR, subject to the applicable rule order and qualified status. | Fiscal years beginning on or after 1 January 2024. |
| IIR / Income Inclusion Rule | Can impose top-up tax at a qualifying Turkish parent level in respect of low-taxed constituent entities outside Türkiye. | Fiscal years beginning on or after 1 January 2024. |
| UTPR / Undertaxed Profits Rule | Acts as a backstop where low-taxed profits are not sufficiently picked up under a QDMTT or IIR, subject to the detailed rule order and safe harbours. | Fiscal years beginning on or after 1 January 2025. |
How Is the 15% Minimum Tax Tested?
Pillar Two does not simply compare the Turkish statutory corporate-tax rate with 15%. It calculates an effective tax rate under GloBE rules on a jurisdictional basis.
If the jurisdictional GloBE effective tax rate is below the minimum rate, a top-up tax computation may be required, after taking into account the detailed GloBE mechanics, substance-based income exclusion, QDMTT, safe harbours and other relevant adjustments.
This is why a Turkish company paying corporate income tax at a headline rate above 15% should not automatically conclude that Pillar Two has no relevance. The GloBE income and covered-tax base can differ materially from Turkish taxable income and ordinary current tax expense.
Why the Turkish QDMTT Matters
A qualified domestic minimum top-up tax is designed to give the local jurisdiction the first opportunity to collect top-up tax on low-taxed domestic GloBE income. For Turkish constituent entities, this means the local QDMTT computation can be a core part of the group’s overall Pillar Two position.
Potential Turkish data inputs can include:
- Financial accounting net income or loss used for GloBE purposes.
- Current and deferred covered taxes.
- Permanent and temporary tax-accounting adjustments.
- Tax incentives and exemptions.
- Qualified and non-qualified tax credits where relevant.
- Payroll and tangible-asset data for the substance-based income exclusion.
- Related-party transactions.
- Prior-year GloBE attributes and elections.
The local team therefore needs more than a Turkish corporate-tax return. It needs a controlled bridge from Turkish financial reporting and tax data into the group’s Pillar Two model.
Turkey Filing Timeline
Türkiye distinguishes local QDMTT reporting from the global minimum top-up tax / GloBE information reporting timetable.
| Filing | General timing | 2024 transition example |
|---|---|---|
| Turkish QDMTT return | Generally by the end of the 12th month following the close of the relevant fiscal year. | For calendar-year 2024, the first filing deadline was ultimately extended to 28 January 2026. |
| Global minimum top-up tax return / GIR-related filing | Generally by the end of the 15th month after the fiscal year, with an 18-month period for the first transitional reporting year. | For calendar-year 2024, the Turkish deadline was extended from 30 June 2026 to 31 July 2026. |
Groups should not build their recurring compliance calendar from first-year extensions. The permanent process should work from the statutory timetable and monitor GİB announcements for any year-specific changes.
GIR and Local Turkish Reporting
The GloBE Information Return, or GIR, is the standardised information package designed to provide tax administrations with the data needed to evaluate Pillar Two calculations.
A group may centrally file the GIR through the ultimate parent or another designated filing entity where the applicable information-exchange arrangements and domestic rules allow it. However, central filing does not automatically mean that the Turkish constituent entity has no local action.
The Turkish compliance analysis should confirm:
- Which entity is the GIR filing entity?
- In which jurisdiction will the GIR be filed?
- Will Türkiye receive the GIR through an effective exchange mechanism?
- Does a Turkish notification remain required?
- Is a separate Turkish QDMTT return required?
- Does the Turkish entity need a local registration or tax-type activation?
- Who is responsible for local payment of any QDMTT or other top-up tax?
Turkish Pillar Two Registration
GİB’s 2026 implementation materials specify a separate tax-registration process for Turkish global minimum top-up tax taxpayers. In particular, Turkish entities that are themselves global minimum top-up tax taxpayers under the IIR / UTPR framework are required to establish the relevant tax liability with their competent tax office under tax code 0064 — Küresel Asgari Tamamlayıcı Kurumlar Vergisi.
The exact registration and filing role should be confirmed against the group’s ownership structure. A foreign-owned Turkish operating subsidiary may have a different role from a Turkish ultimate parent, intermediate parent or partially owned parent entity.
Safe Harbours Can Change the Work — Not the Need for Control
The Pillar Two framework includes transitional and permanent safe harbours designed to simplify compliance or deem top-up tax to be zero when the relevant conditions are satisfied.
Potentially relevant mechanisms can include:
- Transitional CbCR safe harbour.
- QDMTT safe harbour.
- De minimis-type simplifications.
- Simplified calculations for specified constituent entities.
- Other OECD or locally implemented safe-harbour mechanisms available for the relevant period.
Türkiye updated its domestic implementation in July 2026 by publishing jurisdiction lists relevant to the QDMTT safe harbour, QDMTT implementation and IIR application. Those lists and the OECD Central Record should be checked for the relevant fiscal year rather than hard-coded permanently into the group model.
2026 Watchpoint: OECD Side-by-Side Package
In January 2026 the OECD/G20 Inclusive Framework released the Side-by-Side package, adding new safe-harbour architecture for fiscal years beginning on or after 1 January 2026. The package can affect the application of IIR and UTPR for qualifying groups and jurisdictions.
However, QDMTTs remain relevant. A group benefiting from an IIR / UTPR safe harbour may still need to deal with a Turkish QDMTT, local filing and data obligations.
For a Turkish subsidiary, the practical question therefore remains:
What does the group-level safe harbour change, and what Turkish local obligations continue regardless?
Data Collection: The Real Pillar Two Challenge
Most Turkish finance teams do not maintain the local ledger in the same data structure required by the GIR or the group’s GloBE engine. Pillar Two therefore becomes a data-mapping project as much as a tax-calculation project.
| Data category | Potential Turkish source | Control question |
|---|---|---|
| Financial accounting income | Local financial statements / group reporting ledger. | Which accounting standard and reporting package is the GloBE starting point? |
| Current tax | Corporate tax provision and tax return workpapers. | Which taxes qualify as covered taxes? |
| Deferred tax | IAS 12 / TFRS deferred-tax schedule. | Are timing, recast and recapture rules reflected correctly? |
| Payroll | Payroll records and GL. | Which payroll costs qualify for the substance-based income exclusion? |
| Tangible assets | Fixed-asset register. | Can eligible carrying values and locations be supported? |
| Tax incentives | Tax provision and incentive workpapers. | How does the incentive affect covered taxes and GloBE ETR? |
| Related-party transactions | Intercompany ledger / transfer-pricing data. | Are GloBE adjustments or arm’s-length corrections required? |
| Entity information | Legal structure and group master data. | Is each Turkish entity correctly classified for Pillar Two purposes? |
Tax Incentives: 25% Corporate Tax Does Not End the Analysis
Türkiye’s ordinary corporate tax rate may be above the 15% Pillar Two minimum, but incentives, exemptions, credits, losses, deferred-tax positions and GloBE adjustments can still change the jurisdictional effective tax rate.
This is particularly important for groups with Turkish operations benefiting from tax incentives or sector-specific regimes. The group should model the Pillar Two impact of an incentive rather than assuming that an incentive producing a low Turkish cash-tax rate will produce the same result under the GloBE calculation.
The analysis can require coordination between:
- Turkish corporate-tax computation.
- Deferred-tax reporting.
- Investment / R&D incentive schedules.
- Group GloBE model.
- QDMTT calculation.
Pillar Two and IAS 12 / TMS 12
IAS 12 includes a mandatory temporary exception from recognising and disclosing deferred-tax assets and liabilities related to Pillar Two income taxes. It also includes targeted disclosure requirements for entities affected by enacted or substantively enacted Pillar Two legislation.
The accounting workstream should therefore distinguish:
- Ordinary current corporate tax.
- Ordinary deferred tax.
- Pillar Two current top-up tax.
- Required Pillar Two disclosures.
Local QDMTT vs Turkey’s 10% Domestic Minimum Corporate Tax
Türkiye has more than one “minimum tax” concept. They should not be confused.
| Regime | Who it targets | Core rate / concept |
|---|---|---|
| Domestic minimum corporate tax under Article 32/C | Turkish corporate taxpayers generally, subject to the detailed domestic rules. | 10% domestic minimum calculation based on the Turkish corporate-tax framework. |
| Pillar Two QDMTT | Turkish constituent entities of in-scope multinational groups. | 15% GloBE-based minimum effective tax framework. |
The two calculations have different scope, bases and policy objectives. A company can therefore need separate workpapers for ordinary Turkish corporate tax, domestic minimum corporate tax and Pillar Two QDMTT.
How SystemsCPA Structures the Turkish Pillar Two Workstream
Confirm the Turkish entities and group scope
Identify the Turkish constituent entities, permanent establishments, ownership chain and the group’s EUR 750 million threshold position.
Define filing responsibility
Confirm which entity files the GIR, which Turkish notifications / returns are required and who owns local payment obligations.
Map Turkish data
Connect trial balance, tax provision, payroll, fixed assets, deferred tax and intercompany data to the group Pillar Two data request.
Assess safe harbours
Document any available CbCR, QDMTT or other safe harbour based on current Turkish and OECD status.
Support QDMTT calculation
Prepare or reconcile the Turkish local inputs needed for the domestic minimum top-up tax computation.
Reconcile to tax and group reporting
Tie the GloBE inputs back to the Turkish tax provision, deferred-tax schedule and group reporting pack.
Complete local compliance
Support the Turkish registration, notification, return and payment process within the agreed engagement scope.
What Should the Turkish Subsidiary Ask Headquarters?
- Has the group formally concluded that it is in scope of Pillar Two?
- Which entity is the Ultimate Parent Entity?
- Who owns the global Pillar Two model?
- Who will file the GIR?
- Which accounting standard is used as the GloBE starting point?
- Which Turkish data fields are required?
- Which safe harbours does the group expect to rely on?
- Has the group classified Türkiye’s QDMTT and safe-harbour status for the reporting year?
- Which tax incentives or credits require specific GloBE analysis?
- What is the internal data deadline for Türkiye?
- Who approves the Turkish QDMTT calculation?
- How will the Turkish top-up tax be reflected in group tax reporting?
Common Failure Points
Waiting for the return deadline
Pillar Two needs financial, payroll, asset and tax data long before the statutory filing date.
Assuming 25% means no exposure
GloBE ETR is not the same as the Turkish statutory tax rate.
Ignoring QDMTT
Group-level IIR analysis does not replace the local Turkish domestic top-up tax workstream.
No Turkish data owner
Global tax requests become a year-end scramble between local accounting, payroll and fixed assets.
Safe harbour without evidence
The group assumes simplification applies but cannot support the election or qualifying data.
No ledger reconciliation
GloBE data cannot be traced back to Turkish accounting and tax reporting.
What SystemsCPA Can Support
Scope & data
- Turkish entity mapping
- Data-source mapping
- Trial-balance extraction
- Payroll / asset data coordination
- Intercompany data
Tax & QDMTT
- Turkish tax provision bridge
- Covered-tax support
- Deferred-tax input coordination
- QDMTT workpaper support
- Safe-harbour documentation
Local compliance
- Registration support
- Turkish filing calendar
- Notification / return coordination
- Payment workflow
- Group tax communication
Frequently Asked Questions
What is the Pillar Two threshold in Turkey?
The general threshold is consolidated group revenue of at least the Turkish-lira equivalent of EUR 750 million in at least two of the four fiscal years preceding the tested year, subject to the detailed Turkish rules.
What is the Pillar Two minimum tax rate in Turkey?
The GloBE framework applies a 15% minimum effective tax rate calculated on a jurisdictional basis under the Pillar Two rules.
When did Turkey’s Pillar Two rules become effective?
Türkiye’s QDMTT and IIR apply to fiscal years beginning on or after 1 January 2024. UTPR applies to fiscal years beginning on or after 1 January 2025.
What is Turkey’s QDMTT?
The Turkish local minimum top-up tax is the domestic Pillar Two mechanism intended to collect qualifying top-up tax on low-taxed GloBE income arising in Türkiye before that income is subjected to IIR or UTPR elsewhere, subject to the detailed rule order.
Does a Turkish subsidiary need to file even if the group files the GIR abroad?
Potentially yes. Central GIR filing and exchange can reduce duplicate information-return filings, but Turkish notification, QDMTT or other local compliance obligations may remain. The filing role should be confirmed for the specific group structure and reporting year.
When is the Turkish QDMTT return due?
The general Turkish rule is filing and payment by the end of the 12th month following the close of the fiscal year. First-year 2024 calendar-year filings received specific extensions and were ultimately due on 28 January 2026.
When is the Turkish global minimum top-up tax / GIR filing due?
The general framework uses 15 months after fiscal year-end, with an 18-month transitional period for the first reporting year. For calendar-year 2024, Türkiye extended the first global minimum top-up tax filing and payment deadline to 31 July 2026.
Does Turkey’s 25% corporate tax rate mean no Pillar Two top-up tax?
No. Pillar Two uses a GloBE effective tax rate based on adjusted financial accounting income and covered taxes. Tax incentives, losses, credits, deferred-tax effects and other GloBE adjustments can produce a result different from the statutory corporate tax rate.
Is the 10% Turkish domestic minimum corporate tax the same as QDMTT?
No. The 10% domestic minimum corporate tax under Article 32/C is a Turkish corporate-tax calculation. QDMTT is part of the 15% OECD Pillar Two framework for in-scope multinational groups.
Can SystemsCPA work with our global Pillar Two adviser?
Yes. SystemsCPA’s core role can be the Turkish local layer: entity and data mapping, accounting and tax reconciliation, Turkish QDMTT support, filing coordination and communication with the group’s central Pillar Two adviser.
Related SystemsCPA Guides
- Corporate Tax Provision & Deferred Tax in Turkey — current tax, IAS 12 and the tax-reporting bridge beneath Pillar Two.
- Management & Group Reporting in Turkey — Turkish financial data for headquarters reporting.
- Intercompany Accounting & Reconciliation in Turkey — related-party data and group-close controls.
- Turkish Statutory Accounting vs IFRS — financial reporting frameworks and local-to-group adjustments.
- Audit Readiness & Year-End Close Support in Turkey — year-end evidence and reporting controls.
Official Reference Framework
- Turkish Corporate Tax Law as amended by Law No. 7524 — local and global minimum top-up tax provisions.
- GİB — Yerel ve Küresel Asgari Tamamlayıcı Kurumlar Vergisi Uygulama Genel Tebliği, published 26 December 2025.
- GİB — 2026 filing forms, implementation materials and tax calendar.
- Presidential Decision No. 11511, 11 July 2026 — jurisdiction lists for Pillar Two safe-harbour / QDMTT / IIR purposes.
- OECD/G20 Inclusive Framework — GloBE Model Rules, GIR, Central Record and 2026 Side-by-Side Package.
- IAS 12 / TMS 12 amendments relating to Pillar Two income taxes.
Does Your Global Pillar Two Model Reconcile to the Turkish Books?
Send us the group’s Pillar Two data request, Turkish entity list, latest trial balances, tax provision, deferred-tax schedule and incentive profile. We can map the Turkish data, identify local compliance requirements and coordinate the QDMTT / filing workstream with your global tax team.
Request a Turkey Pillar Two Review Explore Tax Provision & Deferred TaxThis material is general information and does not constitute a group-level Pillar Two opinion. Scope, safe-harbour eligibility, top-up tax and filing responsibility should be confirmed for the specific multinational group and fiscal year.
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.
