A Review of Turkey’s Draft Pillar Two Returns

In its 8 April 2026 announcement, the Turkish Revenue Administration (GİB) published draft versions of the Global Minimum Top-up Corporate Tax Return (Küresel Asgari Tamamlayıcı Kurumlar Vergisi Beyannamesi), the accompanying Information Return (Bilgi Beyannamesi), the Notification Form for in-scope Turkish constituent entities, and the General Information Form for MNE groups. The notice also says that in-scope taxpayers must establish a separate “0064 – Küresel Asgari Tamamlayıcı Kurumlar Vergisi” registration and that the forms will be completed through the new e-filing screens rather than delivered by taxpayers in XML/JSON format.

The Turkish filing package operates on two main levels: the Küresel ATV Beyannamesi is Turkey’s domestic tax return for the global top-up tax, while the Küresel ATV Bilgi Beyannamesi is the accompanying GIR-style information filing. The communiqué says the Küresel ATV return is filed with the taxpayer’s corporate-tax office and must include the Bilgi Beyannamesi as an attachment, while the Bilgi Beyannamesi itself is described as a standardised information return that may, in some cases, be satisfied through filing in another jurisdiction under a qualified competent authority arrangement. 

The notice is also important because it clarifies the Turkish filing perimeter. As reproduced from the GİB notice text, the taxpayer for global ATV under the IIR is the Turkish-resident ultimate parent, intermediate parent, or partially owned parent of foreign group entities, and those taxpayers must create the separate 0064 registration with the tax office where they are already registered for corporate tax. The same notice makes clear that even Turkish constituent entities that are not themselves global ATV taxpayers may still have a notification obligation if they belong to an in-scope MNE group.

The global ATV return is due by the end of the 15th month following the end of the accounting period, but the 2024 accounting period benefits from an 18th-month deadline; the same timing applies to the attached global ATV information return. By implication, a taxpayer with a 31 December 2024 year-end is looking at a first Turkish global ATV filing deadline of 30 June 2026.

Review of the draft forms

1) Global Minimum Top-up Corporate Tax Return

The draft Global ATV Return is only four pages, but it captures more than a tax-payment total. It asks for the taxpayer’s VKN, legal name, Pillar Two status, MNE group name, ultimate parent details, the rules applying in the ultimate parent’s jurisdiction, and a separate section identifying the person filing the return. It then includes a distinct block on the attached Information Return, asking whether it will be submitted, where it is filed, which countries and sections are requested to be shared, who filed it, its VKN, its ID number, its filing date, and the relevant contact details.

The return then contains an E section for country-by-country summary data: safe-harbour usage, safe-harbour type, jurisdictional tax burden, the global ATV base, the global ATV rate, the calculated top-up amount, and the amount computed under the IIR. It closes with a total global ATV payable and two annexes: EK 1, the Information Return, and EK 2, the individual financial statements of constituent entities, including the balance sheet and profit/loss statement. This design suggests GİB sees the Turkish return as a short domestic assessment and payment form sitting on top of a much larger information package.

2) The Information Return