| TAX CIRCULAR: 2026-102 | DATE: 01.08.2026 |
Under normal circumstances, these taxpayers provide a guarantee at the rate of 1% of their total annual gross sales. For compliant taxpayers, this rate is applied as one-fifth.
However, with the Tax Procedure Law General Communique No. 594 published in the Official Gazette dated July 31, 2026, and numbered 33326, a significant sanction amendment has been made to the existing Communique No. 531.
5 Times Guarantee Requirement for Issuers or Users of Fake Documents
With the communique amendment, effective as of July 31, 2026:
- Taxpayers against whom a tax inspection report has been issued regarding the arrangement or use of fake or misleading documents,
- During the period between the date the tax inspection reports enter the tax office records and the date the issues in these reports become final,
- Will provide a guarantee equal to 5 times the collateral they are normally required to provide.
Thirty-Day Period
After the date the reports enter the tax office records, taxpayers will be sent an official notification letter asking them to complete their guarantees (to 5 times the amount) within 30 days.
Comparative Summary of Communique Provisions
Previous Application (Before Amendment)
The guarantee is provided at a rate of one-fifth by taxpayers who have the right to benefit from the tax reduction application for compliant taxpayers.
Newly Added Provision (Final Version After Amendment)
a) The guarantee is provided at a rate of one-fifth by taxpayers who have the right to benefit from the tax reduction application for compliant taxpayers.
b) By taxpayers against whom a tax inspection report has been issued in terms of arranging or using fake or misleading documents; 5 times the amount is given during the period between the date the tax inspection reports enter the tax office records and the date the issues in these reports become final. After the date the reports enter the tax office records, taxpayers are requested to complete their guarantees within 30 days with a letter to be notified to them.
