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CONDITIONS FOR CPA CERTIFICATION REPORT ON EXEMPTIONS, DEDUCTIONS AND LOCAL & GLOBAL MINIMUM COMPLEMENTARY CORPORATE TAX IN INCOME AND CORPORATE TAX RETURNS DETERMINED

  • Published by

    Erta Audit

  • Type

    Publication

  • Date

    December 30, 2025

  • Reference

    ertadenetim.com.tr

CONDITIONS FOR CPA CERTIFICATION REPORT ON EXEMPTIONS, DEDUCTIONS AND LOCAL & GLOBAL MINIMUM COMPLEMENTARY CORPORATE TAX IN INCOME AND CORPORATE TAX RETURNS DETERMINED

Communiqué (Serial No: 49) on the Law on Certified Public Accountancy and Sworn-in Certified Public Accountancy was published in the Official Gazette dated December 30, 2025 and numbered 33123.

With the Communiqué, benefiting from exemptions, deductions, and practices included in income and corporate tax returns submitted pursuant to the Income Tax Law and Corporate Tax Law has been made conditional upon the submission of a certification report prepared by sworn-in certified public accountants. In addition, procedures and principles regarding such reports have been determined, including those related to the local and global minimum top-up corporate tax regime regulated under the Corporate Tax Law.

This Circular provides a summary of the exemptions, deductions and applications subject to mandatory certification by sworn-in certified public accountants (YMM) under the Corporate Tax Law, as well as the local and global minimum top-up corporate tax practices.

The following transactions related to exemptions, deductions and applications included in corporate tax returns must be certified by sworn-in certified public accountants and documented through a certification report:

Exemption / Deduction / Application

Relevant Legislation

1- Foreign Subsidiary Income Exemption

Corporate Tax Law No. 5520 (Article 5/1-b)

2- Foreign Share Disposal Gain Exemption

Corporate Tax Law No. 5520 (Article 5/1-c)

3- Share Premium (Emission Premium) Exemption

Corporate Tax Law No. 5520 (Article 5/1-ç)

4- Real Estate Investment Funds/Trusts Income Exemption

Corporate Tax Law No. 5520 (Article 5/1-d/4)

5- Gains from Sale of Real Estate, Participation Shares and Venture Capital Fund Units

Corporate Tax Law No. 5520 (Article 5/1-c and Provisional Article 16)

6- Foreign Construction, Repair and Technical Services Income Exemption

Corporate Tax Law No. 5520 (Article 5/1-h)

7- Industrial Property Rights Exemption

Corporate Tax Law No. 5520 (Article 5/B)

8- Income from Turkish International Ship Registry (TUGS)

Law No. 4490

9- Free Zone Income Exemption

Law No. 3218

10- Technology Development Zone (Technopark) Income Exemption

Law No. 4691

11- R&D Infrastructure Income Exemption

Law No. 6550

12- R&D Deduction

Corporate Tax Law (Repealed Article 10/1-a)

13- Exported Services Deduction

Corporate Tax Law (Repealed Article 10/1-ğ)

14- Interest Deduction on Cash Capital Increase

Corporate Tax Law (Repealed Article 10/1-ı)

15- Reduced Corporate Tax Application

Corporate Tax Law (Articles 32 & 32/A)

16- Local and Global Minimum Top-up Corporate Tax

Corporate Tax Law (Additional Articles 1–13)
 

The certification requirement shall apply for the 2025 fiscal year and subsequent periods. Monetary thresholds have been determined for exemptions and deductions as follows:

  • Where any exemption or deduction exceeds TRY 500,000, all such items shall be subject to certification,
  • Where individual items do not exceed TRY 500,000 but their aggregate exceeds TRY 1,000,000, all shall be subject to certification,
  • Where “Other Deductions and Exemptions” exceeds TRY 1,000,000, all shall be subject to certification,
  • Where total deductions and exemptions exceed TRY 1,000,000, all shall be subject to certification,
  • Where tax advantage under reduced corporate tax exceeds TRY 200,000,
  • Reduced corporate tax (Article 32/A) – regardless of amount,
  • Local and global minimum tax – regardless of amount,

Certification by a sworn-in CPA report is mandatory.

Where a full certification agreement is executed, the above items will be covered in the full certification report, and no separate certification agreement will be required.

The Communiqué entered into force on December 30, 2025.

Yours sincerely.

Official Gazette