| Status | Enacted Law |
| Law | Law No. 7524 on the Amendment of Tax Laws and Certain Laws published in the Official Gazette on August 2, 2024 On October 3, 2025, Turkey published the Draft Communique on the Minimum Tax Law, and the Draft GIR, for consultation. |
| Effective Date | Financial years beginning on or after January 1, 2024 |
| IIR | Yes (2024) |
| UTPR | Yes (2025) |
| QDMTT | Yes (2024) |
| Filing Deadlines | Standard |
| Safe Harbours | Transitional CbCR Safe Harbour, UTPR Safe Harbour |
On October 3, 2025, Turkey published the Draft Communique on the Minimum Tax Law, and the Draft GIR, for consultation.
Whilst Turkey has enacted its Minimum Tax Law, a lot of the detailed application of the GloBE rules was left to a further Regulation. This Communique therefore provides for the detailed rules for the implementation of the GloBE rules in Turkey.
The Law on the Amendment of Tax Laws and Certain Laws” was published in the Turkish Official Gazette on August 2, 2024. Articles 37 – 50 of the Law include provisions to implement the GloBE rules in domestic law from January 1, 2024. This includes the IIR, UTPR (from 2025) and a domestic minimum top-up tax.
GLOBE APPLICATION
General
The Law includes the key aspects of the OECD Model Rules including the general GloBE calculation, de minimis exemption, initial phase of international activity exemption, restructuring rules, provisions for investment companies and Multi-Parented MNE Groups.
However, there are significant aspects of the OECD Administrative Guidance as well as the more detailed aspects of the OECD Model Rules that are not included in the Law. The October 2025 Draft Communique provides for the detailed application of the GloBE rules based on the OECDs Administrative Guidance, as well as including numerous examples to illustrate the implementation in Turkey.
Administrative Guidance
Aspects of the First Set of OECD Administrative Guidance included in the Law are:
-Debt release Election (Article 2.4)
-Equity Gain or loss inclusion election (Article 2.9)
The only aspects of the Second Set of OECD Administrative Guidance included in the Law are Marketable Transferable Tax Credits (aside from the Transitional UTPR Safe Harbour). As such the additional rules for the substance-based income exclusion and currency conversion rules are not included. No aspects of the Third or Fourth Set of OECD Administrative Guidance are included in the Law.
The October 2025 Draft Communique includes numerous other aspects including:
First Set of OECD Administrative Guidance
-Forex hedge election (Article 2.2)
-Excluded Dividends – Asymmetric treatment of dividends and distributions (Article 2.3)
-Accrued Pension Expenses (Article 2.5)
-Excess negative tax carry-forward guidance (Article 2.7)
-Substitute loss-carry forwards (Article 2.8)
-Allocation of taxes arising under Blended CFC Tax Regimes (Article 2.10)
-The extension of the taxable distribution method election to insurance investment entities (Article 3.1)
-Extension of definition of restricted tier 1 capital (Article 3.3)
-Portfolio shareholding election (Article 3.5)
-Transitional Rules (Article 4)
Second Set of OECD Administrative Guidance
SBIE Rules (Article 3):
-Foreign rules
-Stock-based compensation election
-Leases
-Impairment losses inc in tangible asset value
Third Set of OECD Administrative Guidance
-Identifying Consolidated Revenue (Article 3.1)
-Mismatch between Fiscal Years of the UPE and another Constituent Entity (Article 3.2)
-Mismatch between Fiscal Year and Tax Year of Constituent Entity (Article 3.2)
Fourth Set of OECD Administrative Guidance
-General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps (Article 3.1.3)
-Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income (Article 3.1.3)
-Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries (Article 3.1.3)
-Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity (Article 5.2.2)
-Non-group owners: Partially owned Flow-through Entities (Article 5.3.2)
-Non-group owners: Indirect minority ownership (Article 5.3.5)
-Taxes allocated to a flow-through entity (Article 5.4.2)
-Hybrid entities – Taxes pushed down include indirect owners (Article 5.5.2)
-Extension of taxes pushed down to include Reverse Hybrids (Article 5.6.2)
January 2025 OECD Administrative Guidance
The amended Section 12.3.2.1 of the draft Communique includes the deferred tax recognition amendments to Articles 9.1 of the GloBE Rules in the January 2025 OECD Administrative Guidance (including the grace period for DTA reversals). The consequential amendments to the Transitional CbCR Harbour are also included.
Safe Harbour and Penalty Relief Guidance
Article 50(e) of the Law includes the Transitional CbCR Safe Harbour. However, it only provides for this at a high level and outlines the three tests. The detailed rules for applying this (eg including specific adjustments to revenue/profits as provided in the OECD Safe Harbour Guidance) are not included, however, they are included in the October 2025 Draft Communique. This does not, however, yet include the amendments in the Third Set of OECD Administrative Guidance (eg for Hybrid Mismatches).
Article 50(f) of the Law applies the Transitional UTPR Safe Harbour.
The October 2025 Draft Communique also includes the QDMTT Safe Harbour and the NMCE Simplified Calculations Safe Harbour.
ELECTIONS
Elections in the OECD Model Rules
Elections included in the OECD Model Rules provided in the Law are:
-Excluded Entity Election (Article 39(4) of the Law)
-Election to Spread Capital Gains (Article 42(6) of the Law)
-GloBE Loss Election (Article 40(6) of the Law)
-Prior Year Adjustment Election (Article 42(6) of the Law)
-De minimis Election (Article 42(8) of the Law)
-Taxable distribution Election (Article 48(10) of the Law)
-Tax transparency Election (Article 48(9) of the Law)
-Distribution Tax Regime Election (Article 48(5) of the Law)
-Safe Harbour Elections (Article 50 of the Law).
The following are included in the October 2025 Draft Communique:
-Stock-Based Compensation Election (5.2.3 Draft Communique)
-Election to use the Realization Method (5.2.7 Draft Communique)
-Consolidation Election (5.2.9 Draft Communique)
-Unclaimed Accrual Election (6.3.1.1.2 Draft Communique)
-Substance-Based Income Exclusion Election (7.3 Draft Communique)
Elections in the Administrative Guidance
Elections included in the OECD Administrative Guidance that are included in the Law include the:
-Debt release Election (Article 41(b)(4) of the Law)
-Equity Gain or loss inclusion election (41(b)(2) of the Law)
The following are included in the October 2025 Draft Communique:
-Foreign Exchange Hedge Election (5.2.1.3.3 Draft Communique)
-Portfolio Shareholding Election (5.2.1.2.1 Draft Communique)
-Excess Negative Tax Carry-Forward Election (6.1.4.1 Draft Communique)
New Elections
There are no new elections in the Law.
DEVIATIONS FROM THE OECD MODEL RULES/EU GLOBAL MINIMUM TAX DIRECTIVE
Whilst the Law applies the main aspects of the OECD Model Rules, a number of the detailed provisions, as well as the OECD Administrative Guidance are not included. Many of these rules are included in the October 2025 Draft Communique.
DOMESTIC MINIMUM TAX
General
Article 46 of the Law applies a domestic minimum tax from January 1, 2024.
QDMTT Design Features
The amount of top-up tax under the QDMTT is based on the calculation of excess profits for GloBE purposes under Article 46 of the Law.
However, tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules must be excluded, as provided in the OECD Administrative Guidance. This is included in Article 46(2) of the Law.
This preserves Turkey’s primary right to tax income accruing to a Turkish member entity which is also a CFC. If there were no statutory derogation from the general GloBE rules for the calculation of the domestic minimum tax, and the CFC tax paid by the controlling company abroad were included in the included taxes of the Turkish CFC, the effective tax rate would be increased. Therefore, excluding the CFC tax from the Turkish CFCs covered taxes allows Turkey to tax low-taxed income at a higher rate than would be the case under an IIR.
Article 46(2) also prevents the pushdown of tax to hybrids, PEs and for taxes on distributions (aside from Turkish withholding tax on distributions).
Whilst the July 2024 OECD Administrative Guidance does permit local accounting standards to be used for QDMTT purposes, Turkey simply adopts the default GloBE rules. As such the accounting standard of the UPE is used unless an exception applies.
Article 46 specifically applies the de minimis exception for the purposes of the domestic minimum tax.
Article 4.2.2 of the Draft Communique also provides that it applies irrespective of the shareholdings in the group entities located in Turkey. This reflects the OECD Administrative Guidance that provides that Top-up Tax that is subject to the QDMTT is based on the whole amount of the jurisdictional Top-up Tax calculated, irrespective of the ownership interests held in the Constituent Entities located in the QDMTT jurisdiction by any Parent Entity of the MNE Group.
Article 4.2.2 of the Draft Communique excludes the GloBE loss election for QDMTT purposes.
Registration
Not provided.
Filing
The relevant aspects of the submission of a GloBE Information Return (GIR) are included, as provided in the OECD Guidance.
The proposed approach is that every Constituent Entity located in Turkey will have an obligation to file a GIR in Turkey. However, this obligation can be discharged if the GIR is filed by:
Where the GIR is being filed by either the Ultimate Parent Entity or the Designated Filing Entity, the Constituent Entity, must file a notification with the Revenue.
The notification must contain:
Where the GIR is filed by the Designated Local Entity it needs to outline the Constituent Entities that it is filing on behalf of.
Both the GIR and associated notifications must be filed no later than 15 months after the end of the fiscal year (with an 18-month deadline for the Transition Year).
Article 44 of the Law requires submission of an IIR/UTPR self- assessment return (a ‘GloBE Top-Up Tax Return’) within 15 months after the end of the fiscal year (with an 18-month deadline for the Transition Year)
Article 46(3) requires submission of a DMT self- assessment return (a ‘DMT Top-Up Tax Return’) within 12 months of the end of the accounting period.
Payment
Article 46 provides that the payment deadline for the domestic minimum top-up tax is 12 months from the end of the accounting period.
On October 3, 2025, Turkey published the Draft GIR for consultation.
| Turkey | |||
|---|---|---|---|
| Effective Date: | Fiscal years beginning on or after January 1, 2024 | ||
| Section/Article | |||
| First Set of OECD Administrative Guidance | |||
| 1.1 | Rebasing monetary thresholds in the GloBE Rules | 2.1.1 Draft Communique | |
| 1.2 | Deemed consolidation test | – | |
| 1.3 | Consolidated deferred tax amounts | – | |
| 1.4 | Sovereign wealth funds and the definition of Ultimate Parent Entity | 2.2.4.1 Draft Communique | |
| 1.5 | Clarifying the definition of ‘Excluded Entity’ | – | |
| 1.6 | Meaning of ancillary for Non-Profit Organisations | 3.2.2.1 Draft Communique | |
| 2.1 | Intra-group transactions accounted at cost | – | |
| 2.2 | Excluded Equity Gains or Loss and hedges of investments in foreign operations | 5.2.1.3.3 Draft Communique | |
| 2.3 | Excluded Dividends- Asymmetric treatment of dividends and distributions | 5.2.1.2 Draft Communique | |
| 2.4 | Debt release Election | 41(b)(4) |
|
| 2.5 | Accrued Pension Expenses | 5.2.1.9 Draft Communique | |
| 2.6 | Covered Taxes on deemed distributions | – | |
| 2.7 | Excess Negative Tax Carry-forward guidance | 6.3.1.1.5 Draft Communique | |
| 2.8 | Substitute Loss carry forwards | 6.1.4.1 Draft Communique | |
| 2.9 | Equity Gain or loss inclusion election | 41(b)(2) |
|
| 2.9 | Qualified Ownership Interest/Flow through entity | 5.2.1.3.4 Draft Communique | |
| 2.1 | Allocation of taxes arising under a Blended CFC Tax Regimes | 6.2.3.1 Draft Communique | |
| 3.1 | Application of Taxable Distribution Method Election to Insurance Investment Entities | 9.4.3 Draft Communique | |
| 3.2 | Exclusion of Insurance Investment Entities from the definition of Intermediate Parent Entity and Partially-Owned Parent Entity | – | |
| 3.3 | Restricted Tier 1 Capital | 5.2.11 Draft Communique | |
| 3.4 | Liabilities related to Excluded Dividends and Excluded Equity Gain or Loss from securities held on behalf of policyholders | – | |
| 3.5 | Simplification for Short-term Portfolio Shareholdings | 5.2.1.2.1 Draft Communique | |
| 3.6 | Application of Tax transparency election to Mutual insurance companies | – | |
| 4.1 | Deferred tax assets with respect to tax credits under Article 9.1.1 | 12.3.1 Draft Communique | |
| 4.2 | Applicability of Article 9.1.3 to transactions similar to asset transfers | 12.4 Draft Communique | |
| 4.3 | Asset carrying value and deferred taxes under 9.1.3 | 12.4 Draft Communique | |
| Second Set of OECD Administrative Guidance | |||
| 1 | Currency conversion rules | – | |
| 2 | MTTCs | 40 |
|
| 3 | SBIE Rules | – | |
| – Foreign rules | 7.3.1.2/7.3.2.1 Draft Communique | ||
| Stock-based compensation election | 7.3.1.3 Draft Communique | ||
| Leases | 7.3.2.1.1 Draft Communique | ||
| – Impairment losses inc in tangible asset value | 7.3.2.3 Draft Communique | ||
| 4.1 | QDMTT Safe Harbour | 11.4 Draft Communique | |
| 4.2 | UTPR Safe Harbour | 11.2 Draft Communique | |
| Third Set of OECD Administrative Guidance | |||
| 1 | Transitional CbCR – Purchase Accounting Adjustments (consistent reporting condition, goodwill impairment adjustment) | – | |
| 2.2.1 | Transitional CbCR – JVs | – | |
| 2.3.1 | Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting | – | |
| 2.3.2 | Transitional CbCR – Using different accounting standards | – | |
| 2.3.3 | Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches | – | |
| 2.3.4 | Transitional CbCR – MNEs not required to file CbC Reports | – | |
| 2.3.5 | Transitional CbCR – Qualified Financial Statements for PEs | – | |
| 2.4.2 | Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities | – | |
| 2.6 | Transitional CbCR – Treatment of hybrid arbitrage arrangements | – | |
| 3.1 | Identifying Consolidated Revenue | 2.1.1 Draft Communique | |
| 3.2 | Mismatch between Fiscal Years of the UPE and another Constituent Entity | 2.1.1 Draft Communique | |
| 3.3 | Mismatch between Fiscal Year and Tax Year of Constituent Entity | 6.1 Draft Communique | |
| 4.2.1 | Blended CFCs -multiple GloBE Jurisdictional ETRs | – | |
| 4.2.2 | Blended CFCs – not required to calculate an ETR | – | |
| 4.2.3 | Blended CFCs – income of non-GloBE Entities | – | |
| 5.3 | 30 June 2026 Filing deadline | – | |
| 6 | NMCE Simplified Calcs | 11.3 Draft Communique | |
| Fourth Set of OECD Administrative Guidance | |||
| 1.2.1 | Aggregate DTL Category basis | – | |
| 1.2.1 | Exclusion of certain types of GL accounts and separate tracking | – | |
| 1.2.1 | Exclusion of GL accounts that generate standalone DTAs | – | |
| 1.2.1 | Exclusion of swinging accounts and separate tracking | – | |
| 1.2.2 | FIFO/LIFO Basis | – | |
| 1.2.3 | Aggregation of Short-term DTLs | – | |
| 1.2.2 | Reversal of DTLs that accrued before the Transition Year | – | |
| 1.2.2 | 5 year unclaimed accrual election | – | |
| 2.1.2 | Recalculated deferred tax where GloBE carrying value differs from accounting carrying value | – | |
| 2.1.2 | GloBE and accounting carrying values and the Transition Rules | – | |
| 2.1.2 | Additional provisions for Intragroup transactions accounted for at cost | – | |
| 2.1.2 | Exclusion of GloBE carrying value from SBIE | – | |
| 3.1.3 | General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps | 6.2.1 Draft Communique | |
| 3.1.3 | Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income | 6.2.1 Draft Communique | |
| 3.1.3 | Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries | 6.2.1 Draft Communique | |
| 4.1 | Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids | – | |
| 4.2 | Allocation of deferred tax expenses and benefits from a Parent Entity to a CFC, PE Hybrid or Rev Hybrid: 5 step process | – | |
| 4.2.2 | Five-Year Election to exclude the allocation of all deferred tax expenses and benefits to CFCs, PEs, Hybrids and Rev Hybrids | – | |
| 4.2.3 | Exclusion of deferred tax assets or liabilities arising under a Blended CFC regime from transition rules | 12.3.1 Draft Communique | |
| 5.2.2 | Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity | 5.4.2 Draft Communique | |
| 5.3.2 | Non-group owners: Partially owned Flow-through Entities | 5.4.3 Draft Communique | |
| 5.3.5 | Non-group owners: Indirect minority ownership | 5.4.3 Draft Communique | |
| 5.4.2 | Taxes allocated to a flow-through entity | 6.2.2 Draft Communique | |
| 5.5.2 | Hybrid entities – Taxes pushed down include indirect owners | 6.2.4 Draft Communique | |
| 5.5.4 | Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system | – | |
| 5.6.2 | Extension of taxes pushed down to include Reverse Hybrids | 6.2.4 Draft Communique | |
| 6.1.4 | Option to exclude a Securitization Entity from scope of QDMTT | – | |
| 6.1.4 | Option to not impose top-up tax liabilities on SPVs used in securitization transactions | – | |
| 6.1.4 | Amendments to the Switch-Off rule | – | |
| 6.1.4 | New definition: Securitization Entity | – | |
| 6.1.4 | New definition: Securitization Arrangement | – | |
| January 2025 OECD Administrtive Guidance | |||
| 1 | Articles 8.1.4 and 8.1.5 | ||
| 1 | Amendments to CbCR Safe Harbour for 9.1 | 12.3.2.1 Draft Communique | |
| 1 | Amendments to QDMTT Safe Harbour for 9.1 | ||
| 1 | Article 9.1 of the GloBE Rules | 12.3.2.1 Draft Communique | |
| 1 | Central Record of Legislation with Transitional Qualified Status |
| Note | Turkey | |
|---|---|---|
| QDMTT?(Enacted/Draft) | Is there a QDMTT in the Legislation? | Yes – Enacted |
| Effective Date: | Fiscal years beginning on or after January 1, 2024 | |
| Administrative Guidance/Safe Harbour Guidance? | Are the provisions of the OECD Administrative Guidance and Safe Harbour Guidance reflected in the current legislation? | Limited aspects |
| Separate/Transposed QDMTT | Is the QDMTT a Separate QDMTT or a Transposition of the GloBE Rules (with Amendments) | Transposed |
| Domestic Groups | A QDMTT can also apply to purely domestic groups. | No |
| Scope Definitions | The definitions of Ultimate Parent Entity, MNE Group, and Constituent Entity correspond with the definitions in the GloBE Rules. | Transposed Art 46(2) |
| Income and covered taxes of Constituent Entities | The QDMTT must compute the tax liability for the jurisdiction by taking into account the income and covered taxes of Constituent Entities under the GloBE Rules. | Transposed Art 46(2) |
| Separate ETRs | A QDMTT must determine a separate ETR and Top-up Tax amount for MOCEs, Joint Ventures and JV Subsidiaries. | Transposed Art 46(2) |
| Charging | A QDMTT must impose a Top-up Tax on one or more domestic Constituent Entities on the Excess Profits of all domestic Constituent Entities, including the domestic Parent Entity. | |
| Enforceability | The legal liability for the domestic top-up tax needs to be enforceable against at least one Constituent Entity in the jurisdiction. | |
| Different Accounting Standard? – Optional | Is the use of a local accounting standard optional? | No |
| Different Accounting Standard? – Mandatory | Is the AG2 guidance followed? | No |
| Different Accounting Standard? – Default GloBE rules | Do the general GloBE rules apply for the QDMTT accounting standard? | Yes – Enacted |
| Require 100% ownership? | The QDMTT )can require 100% ownership | No |
| Differences to GloBE Rules: tighter restriction is consistent with local tax rules | The QDMTT can be more restrictive than the GloBE Rules where the tighter restriction is consistent with local tax rules. | None |
| Differences to GloBE Rules: Not relevant to in the context of its domestic tax system | The QDMTT can exclude adjustments that are not relevant to in the context of its domestic tax system. | None |
| Income/Loss of a PE | The QDMTT must exclude the income or loss of a foreign Permanent Establishment from the income or loss of the Main Entity. | Transposed Art 46(2) |
| Tax Transparency | A QDMTT must include certain tax transparent provisions. | Transposed Art 46(2) |
| Adjusted Covered Taxes Consistency | The range of taxes included in Covered Taxes needs to be the same or narrower, as under the GloBE rules. | Transposed Art 46(2) |
| GloBE Loss Election? | Not Required in QDMTT | Transposed Art 46(2) |
| No Pushdown to CFC or PE | A QDMTT must exclude: (1) tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules and (2) tax paid or incurred by a Main Entity that is allocated to a PE in the jurisdiction. | Art 46(2) |
| Exclude tax allocated to Hybrids | Second AG Guidance | Art 46(2) |
| Exclude allocated net basis tax on dividends (except WHT) | Second AG Guidance | Transposed Art 46(2) |
| UPE that is a Flow-Through Entity | Second AG Guidance | Transposed Art 46(2) |
| UPE subject to Deductible Dividend Regime | Second AG Guidance | Transposed Art 46(2) |
| Eligible Distribution Tax Systems | Second AG Guidance | Transposed Art 46(2) |
| ETR Computation for Investment Entities | Second AG Guidance | Transposed Art 46(2) |
| Investment Entity Tax Transparency Election | Second AG Guidance | Transposed Art 46(2) |
| Taxable Distribution Method Election | Second AG Guidance | Transposed Art 46(2) |
| Multi-Parented MNE Groups | Second AG Guidance | Transposed Art 46(2) |
| Additional Top-Up Tax/Excess Negative Tax Expense | A QDMTT needs to have provisions for additional top-up tax where there is no Net GloBE Income and the Adjusted Covered are less than zero and less than the Expected Adjusted Covered Taxes. Amount. Excess Negative Tax Carry-forward rules also need to be in place. | Art 46(2) |
| Modified Top-Up Tax Formula | The QDMTT top-up tax formula needs to be modified as the GloBE Rules subtract tax paid under a QDMTT from the current GloBE Top-up Tax. | Art 46(2) |
| Same Approach As GloBE Rules | A QDMTT must require that top-up tax is taken into account by the relevant Constituent Entity at the same time and in the same manner as under the GloBE Rules (eg it can’t be carried forward). | Transposed Art 46(2) |
| SBIE Included? | Not Required in QDMTT | Transposed Art 46(2) |
| SBIE Rates same as GloBE? | Not Required in QDMTT | Transposed Art 46(2) |
| De Minimis Rule Included? | Not Required in QDMTT | Art 46(4) |
| Restructuring Rules? | A QDMTT needs to include restructuring rules as provided in the GloBE rules to the extent necessary to conform to the tax reorganization rules in the jurisdiction. | Transposed Art 46(2) |
| Safe Harbours? | A QDMTT needs to contain GloBE safe harbours. | Transposed Art 46(2) |
| Deferred Tax Transition Rule? | A QDMTT must include the deferred tax starting point under Article 9.1.1 of the Model Rules. | |
| SBIE Transitional Rates? | Not Required in QDMTT | |
| Initial Phase of International Activity Exemption | Not Required in QDMTT | Transposed Art 46(2) |
| Elections? | Where the GloBE Rules permit an election, a QDMTT must generally also provide for the election and require the MNE Group to make the same election under the QDMTT as is made under the GloBE Rules. | Transposed Art 46(2) |
| Deferred Tax transition: First time or refreshing rule? | Second AG | |
| New transition year – amend tax attributes? | Second AG | |
| Currency provisions? | Second AG | |
| DTL Recapture rules – Aggregate DTL Categories | Fourth AG, 1.2.8 | |
| DTL Recapture rules Unclaimed Accrual Five-Year Election | Fourth AG, 1.2.8 | |
| Reverse Hybrid Pushdown | Fourth AG, 5.6.2 | |
| Securitization Entities – A QDMTT may also exclude a Securitisation Entity from its scope | Fourth AG, 6.1.4 | |
| Securitization Entities – A jurisdiction may allocate the QDMTT liability for any QDMTT top-up tax to another Constituent Entity (if any) that is located in the jurisdiction | Fourth AG, 6.1.4 | |
| Note |
| Turkey | ||
|---|---|---|
| Effective Date: | Fiscal years beginning on or after January 1, 2024 | |
| Section/Article | ||
| Safe Harbour & Penalty Relief Guidance | De Minimis Test | 50(e) |
| Safe Harbour & Penalty Relief Guidance | Simplified ETR Test | 50(e) |
| Safe Harbour & Penalty Relief Guidance | Routine Profits Test | 50(e) |
| Safe Harbour & Penalty Relief Guidance | Simplified Covered Tax defn (inc exclusion of uncertain tax positions) | – |
| Safe Harbour & Penalty Relief Guidance | Simplified ETR defn | – |
| Safe Harbour & Penalty Relief Guidance | Transition Period | 50(e) |
| Safe Harbour & Penalty Relief Guidance | Transition Rate | 50(e) |
| Safe Harbour & Penalty Relief Guidance | Defn of Qualified Financial Statements | – |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Joint Ventures | – |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Tax Neutral UPEs | – |
| Safe Harbour & Penalty Relief Guidance | Special Rules for Investment Entities and their Constituent Entity-owners | – |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Net Unrealised Fair Value Loss | – |
| Safe Harbour & Penalty Relief Guidance | Exclusions | – |
| December 2023 OECD Administrative Guidance | ||
| 1 | Transitional CbCR – Purchase Accounting Adjustments(consistent reporting condition, goodwill impairment adjustment) | – |
| 2.2.1 | Transitional CbCR – JVs | – |
| 2.3.1 | Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting | – |
| 2.3.2 | Transitional CbCR – Using different accounting standards | – |
| 2.3.3 | Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches | – |
| 2.3.4 | Transitional CbCR – MNEs not required to file CbC Reports | – |
| 2.3.5 | Transitional CbCR – Qualified Financial Statements for PEs | – |
| 2.4.2 | Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities | – |
| 2.6 | Transitional CbCR – Treatment of hybrid arbitrage arrangements | – |
| January 2025 OECD Administrtive Guidance | ||
| Amendments to CbCR Safe Harbour for 9.1 |
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