Turkey's Global Minimum Tax Framework Takes Shape: Draft Returns and Notification Forms Published
What Happened?
The Turkish Revenue Administration (TRA) published its announcement on April 8, 2026 regarding the filing and notification obligations under the Global Minimum Top-up Corporate Tax (Global Top-up Tax). The draft documents attached to the announcement constitute an important reference point for understanding the overall reporting framework.
The four draft documents published alongside the announcement are intended for preliminary information purposes and will be implemented in their final form through the new e-declaration system. Taxpayers and in-scope multinational enterprise (MNE) groups should treat these drafts as a foundational resource in preparing for the upcoming filing cycle.
Legal Framework: IIR and UTPR
Article Additional 7 of Corporate Tax Law No. 5520 provides that the Global Top-up Tax will be applied under the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR). Under the IIR, Turkey exercises its right to collect top-up tax on low-taxed income of foreign constituent entities through the Turkish-resident parent entities of MNE groups. The UTPR functions as a secondary backstop mechanism for situations where the IIR cannot be applied.
Taxpayer Identification: Who Files a Return, Who Submits a Notification?
A critical distinction must be drawn here.
Entities classified as Global Top-up Tax taxpayers under Article Additional 7 of the CTL — that is, Turkish-resident ultimate parent entities, intermediate parent entities, or partially-owned parent entities of MNE groups — are required to register for the "0064 – Global Minimum Top-up Corporate Tax" taxpayer status at the tax office to which they are affiliated for corporate tax purposes, and to file a return accordingly. Since taxpayer registration is a prerequisite for the filing obligation, this step must be completed in a timely manner.
On the other hand, Turkish constituent entities that are not Global Top-up Tax taxpayers but are members of in-scope MNE groups are not exempt from obligations. While no return-filing requirement is imposed on these entities, a separate notification mechanism will apply to them. Accordingly, the fact that a Turkish entity is not a Global Top-up Tax taxpayer does not mean it bears no compliance obligations whatsoever.
The Draft Document Set: Four Documents, Distinct Roles
The TRA's announcement covers a set of four draft documents.
1-Global Top-up Tax Return
This document serves as the main return for Global Top-up Tax taxpayers. Under the IIR, the effective tax rate (ETR), safe harbour status, Global Top-up Tax base, calculated tax amount, and the portion of tax attributable to the taxpayer will each be reported on a country-by-country basis. In addition to the return itself, taxpayers are required to submit the Global Top-up Tax Information Return and the individual financial statements of constituent entities as attachments.
A notable requirement here is the obligation to ensure consistency between consolidated reporting data and individual financial statements. GloBE calculations are inherently based on consolidated figures; however, the Turkish administration also requires a view of each constituent entity's individual financial position. Any inconsistency between the two data sets may give rise to explanation obligations in the event of a review.
2-Global Top-up Tax Information Return
This return, which closely mirrors the OECD's GloBE Information Return (GIR) format, is the document through which comprehensive technical details of Global Top-up Tax calculations are reported. Its content covers group structure and ownership relationships, country-level income and covered tax data, deferred tax adjustments, Substance-Based Income Exclusion (SBIE) calculations, qualified domestic minimum top-up tax (QDMTT) applications, and detailed tables on the allocation of tax under the IIR and UTPR across jurisdictions.
Submission of this return to Turkey is not mandatory — it is optional. However, taxpayers that choose to submit the Information Return must do so as an attachment to the Global Top-up Tax Return. Groups that file their GIR in another jurisdiction should carefully consider how that choice is reflected in their notification form obligations.
One important technical point regarding the filing method: neither of these two returns will be required in XML/JSON format. Both will be completed through screen-based forms on the new e-declaration system. This is a practical decision that directly affects data preparation and system integration processes.
3-Global Top-up Tax Notification Form
This four-part form is designed specifically for Turkish constituent entities that are not Global Top-up Tax taxpayers. It covers the identifying information of the notifying entity, general information about the MNE group, a declaration as to whether a Turkish-resident Global Top-up Tax taxpayer exists within the group, and information about the jurisdiction in which the GIR has been submitted.
The critical branching point in the form is as follows: if a Turkish-resident Global Top-up Tax taxpayer exists, the form is limited to basic identification and taxpayer information. If no such taxpayer exists, the notifying entity is required to explicitly state whether the jurisdiction in which the GIR was filed is a party to the GIR Multilateral Competent Authority Agreement (GIR-MCAA). It should be noted that Turkey is not yet a party to the GIR-MCAA — a fact that, particularly for groups filing their GIR outside Turkey, serves as the primary trigger for the obligation to submit the fourth document.
4-General Information Form on the Multinational Enterprise Group
This form is triggered when the Notification Form bears the selection "GIR has not been submitted" or "GIR has been submitted in a jurisdiction that is not a party to the GIR-MCAA," and must be submitted as an annex to the Notification Form.
In terms of content, the form constitutes a subset of the GIR and covers the corporate structure, ownership relationships, and Global Top-up Tax status of each constituent entity across the entire MNE group, including the ultimate parent entity (UPE). Its purpose is to enable the Turkish administration to access at least the fundamental and critical information about the group in situations where it cannot obtain the GIR directly. In this regard, the form requires the centralized and consistent reporting of data pertaining not just to the Turkish constituent entity, but to the group as a whole.
Assessment: Points Worth Noting
Taken as a whole, the draft documents raise several points worth highlighting.
Turkey's non-signatory status to the GIR-MCAA prevents automatic information flow for Turkish constituent entities of groups that file their GIR outside Turkey. The administration is seeking to close this gap through the General Information Form. Groups should factor this outcome into their GIR strategy decisions.
The alignment of the Information Return with the GIR format is a welcome development; however, the technical differences between the two documents will need to be examined in detail. Groups that opt to submit an Information Return specifically for Turkey may not be able to use their existing GIR infrastructure directly — an additional adaptation process may be required.
What Should Be Done?
June 30, 2026 is the filing deadline for the Global Top-up Tax return for the 2024 fiscal year. The principal steps to be completed by that date can be outlined as follows:
First, the status of each Turkish entity — whether it is a Global Top-up Tax taxpayer or merely a constituent entity with a notification obligation — must be clearly established. This determination directly dictates which document needs to be prepared and which data set needs to be compiled.
Next, a group-wide decision must be made as to whether the GIR will be filed in Turkey or in another jurisdiction. This choice shapes both the scope of the Information Return and whether the obligation to submit the General Information Form will be triggered.
From a data preparation standpoint, it is strongly advisable to verify consistency between consolidated financial data and individual entity financial statements at an early stage — this is an area that can create significant time pressure if addressed too late in the process.
Finally, since different types of obligations may apply to different Turkish entities within the same group, it is essential that the filing and notification processes be managed within a centralized coordination framework across the group.
The announcement published by the Turkish Revenue Administration, together with the draft tax returns and notification forms regarding the Global Minimum Top-up Corporate Income Tax, is available on the official website of the Turkish Revenue Administration via the link below:
Turkish Revenue Administration Related Page
