Türkiye’s global minimum tax rules have introduced new reporting and notification responsibilities for constituent entities of multinational enterprise groups. In general, the rules apply when the group’s annual consolidated revenue exceeds the Turkish lira equivalent of EUR 750 million in at least two of the four fiscal years preceding the relevant fiscal year. Each Turkish constituent entity must therefore be assessed according to the group structure, its tax status and the jurisdiction in which the GloBE Information Return will be filed. Pillar Two Türkiye should consequently be treated as a coordinated compliance process rather than solely as a tax calculation exercise.
Effective global minimum tax readiness requires companies to identify their Turkish entities, obtain current information from the ultimate parent entity, appoint the entity responsible for the notification and verify all data before electronic submission. Tax, accounting, legal and financial reporting teams must work with the group headquarters through a controlled information flow. Inconsistencies involving legal names, tax identification numbers, entity classifications, reporting periods or GIR filing details may create significant compliance and reconciliation risks.
What Is the Global Minimum Top-Up Corporate Tax Notification Form?
The global minimum top-up corporate tax notification form is an electronic form designed to provide the Turkish Revenue Administration with information about an in-scope MNE group and its constituent entities in Türkiye. It primarily concerns Turkish constituent entities that belong to an in-scope group but are not themselves global minimum top-up corporate taxpayers in Türkiye. The form identifies the notifying entity, the MNE group, the ultimate parent entity and other Turkish constituent entities included in the notification.
The form does not directly calculate a top-up tax or create a tax assessment. Its principal purpose is to inform the tax authority which entity is making the notification and where and by whom the group’s GIR will be filed. Nevertheless, the global minimum top-up corporate tax notification is closely connected with the tax return and information return. Fiscal-year details, constituent entity classifications, ultimate parent information and GIR filing data must therefore remain consistent across all relevant documents.
Which Companies Must Submit the Global Minimum Tax Notification Form?
The first step is to determine whether the group qualifies as an MNE group and meets the consolidated revenue threshold under Turkish Corporate Tax Law No. 5520. Groups that do not exceed the Turkish lira equivalent of EUR 750 million in at least two of the four fiscal years preceding the relevant fiscal year are generally outside the scope. If the threshold is exceeded, every Turkish group entity must be reviewed separately.
Turkish entities that qualify as global minimum top-up corporate taxpayers fulfil their obligations through the applicable tax return and accompanying information return. According to the Turkish Revenue Administration’s published framework, constituent entities that belong to an in-scope group but are not global minimum top-up corporate taxpayers in Türkiye may be required to submit the notification form. The MNE group notification obligation must therefore be evaluated by considering the group threshold, entity location, ownership structure and Pillar Two classification together.
How Are Turkish Constituent Entities Within an MNE Group Identified?
Companies should begin with the consolidation perimeter used by the ultimate parent entity and identify all subsidiaries, branches, joint ventures and specially classified group entities operating in Türkiye. The legal name, tax identification number, tax office, ownership structure, consolidation method and Pillar Two status of each entity should be documented. Mergers, demergers, share transfers, liquidations and incorporations occurring during the fiscal year must also be reviewed. The analysis should not rely solely on the group structure existing at the fiscal year-end if changes during the period affect the entity classification.
Which Constituent Entity Can Submit the Notification on Behalf of the Group?
The notification framework allows a Turkish constituent entity to include other Turkish entities belonging to the same MNE group by reporting their legal names and tax identification numbers. When selecting the notifying entity, the group should consider electronic filing authority, access to group-level data and communication responsibilities with the ultimate parent entity. The appointment should be documented through an internal authorisation or management decision. A controlled list of entities covered by the filing also helps prevent duplicate notifications and ensures that no Turkish entity is inadvertently omitted.
What Is the Difference Between the Notification Form, Tax Return and Information Return?
The global minimum tax notification form, the top-up corporate tax return and the global minimum tax information return belong to the same reporting framework but serve different purposes. The tax return reports the top-up tax calculated under the Income Inclusion Rule and may result in a payment obligation in Türkiye. The GIR contains more detailed information about the group structure, jurisdictional effective tax rates, safe harbours, elections and Pillar Two calculations.
| Document | Primary purpose | General filing party | Tax assessment |
| Notification form | Reports the group, Turkish entities and GIR filing location | An in-scope Turkish constituent entity that is not a global minimum top-up corporate taxpayer | Does not create an assessment |
| Global minimum top-up corporate tax return | Reports the tax calculated under the applicable IIR provisions | Turkish global minimum top-up corporate taxpayer | May create a tax liability |
| GloBE Information Return | Reports group and jurisdiction-level calculations | Ultimate parent entity or designated filing entity | Does not independently create a tax assessment |
Although these documents have different functions, their data cannot be prepared independently. An entity should not be classified as a constituent entity in one document and as an intermediate parent entity in another without a valid legal basis. The group name, reporting period, ultimate parent entity, GIR filing entity and identification details should come from a common master data source. A document-to-document reconciliation should be completed before submission.
What Information Is Required in the Notification Form?
The notification form generally contains four principal information categories. These cover the Turkish entity submitting the notification, the relevant MNE group and ultimate parent entity, any Turkish global minimum top-up corporate taxpayer and the entity responsible for filing the GIR. The sections that must be completed depend on whether the group has a global minimum top-up corporate taxpayer in Türkiye and where the information return will be submitted.
Before completing the form, companies should collect trade registry records, the current group organisation chart, consolidated financial statements, tax identification information and written confirmations received from the ultimate parent entity. The electronic fields and current guidance should be reviewed again at the time of submission. Where an entity’s name, address, ownership or group status changed after the reporting period, the company should document which information applies to the relevant fiscal year.
Information About the Notifying Entity and MNE Group
The form requires the notifying entity’s tax identification number, legal name and registered tax office. Group-related fields generally cover the MNE group’s name and the ultimate parent entity’s legal name, jurisdiction and registered address. Other Turkish constituent entities may also be listed using their legal names and tax identification numbers. These details should be compared with trade registry records, Digital Tax Office information and the group’s consolidation records to prevent the use of abbreviated names, outdated addresses or incorrect jurisdiction codes.
Information About Global Minimum Taxpayer Status and GIR Filing
The form asks whether the group has a Turkish entity classified as a global minimum top-up corporate taxpayer. If the answer is affirmative, the taxpayer’s identification number, legal name, tax office and Pillar Two status must generally be reported. If no such taxpayer exists, the GIR-related section becomes relevant. This section may require the GIR filing jurisdiction, the filing entity’s role and legal name, tax identification number, return ID, filing date and contact-person details. Each item should be supported by group records or formal filing evidence.
How Is the Notification Made When the GIR Is Filed in Another Jurisdiction?
Where the information return is filed outside Türkiye, the company must first determine whether the foreign jurisdiction can exchange GIR information with Türkiye for the relevant reporting period. A general statement from the group headquarters that the return will be filed abroad is not sufficient. The filing entity’s role, jurisdiction, identification number, return ID, filing date and authorised contact person should be confirmed in writing.
Information used for the GIR filing should ideally be obtained after the foreign submission is completed and supported by filing evidence. If the foreign return has not yet been submitted, the information should be based on an approved and sufficiently final group reporting plan. The current GIR MCAA position and activated exchange relationships should be checked using the OECD’s Pillar Two resources, as participation in the agreement does not automatically confirm that every bilateral exchange relationship is effective.
Filing the GIR in a GIR MCAA Participating Jurisdiction
If the GIR is submitted in Türkiye or in a jurisdiction through which an effective GIR exchange mechanism applies, the Turkish notification should identify the foreign filing entity and the relevant return details. The entity’s Pillar Two role, legal name, identification number, return ID, filing date and contact person must be reported consistently. The return ID should be taken directly from the filing confirmation, while the contact person should be someone capable of responding to information requests. The applicable exchange relationship must be verified for the specific reporting period rather than assumed from a general signatory list.
Filing the GIR Outside the GIR MCAA Framework or Not Filing It Abroad
If the GIR is filed in a jurisdiction from which the relevant information cannot be exchanged with Türkiye, or if no foreign GIR is filed, additional group information may be required under the Turkish notification framework. This information can include constituent entities, ownership relationships, Pillar Two classifications and corporate changes occurring during the period. Companies should therefore review the exchange status early. If supplementary group reporting may be necessary, ownership and entity-level data should be collected well before the Turkish filing deadline.
How Should Companies Begin Preparing the Notification Form?
Preparation should begin with a written scope assessment explaining whether the group meets the revenue threshold and how each Turkish entity is classified. The responsible entity, other Turkish entities covered by the notification and the foreign entity filing the GIR should then be identified. A central working file should assign a data owner, documentary source, reviewer and approval date to every required field. This approach creates a clear audit trail and highlights missing information before filing begins.
A trial completion using the available form structure can reveal data gaps before the electronic filing period. STB CPA Turkey can support the assessment of the consolidated revenue threshold, classification of Turkish entities, mapping of form fields to supporting documents and preparation of an information request for the ultimate parent entity. The process can consequently be managed as an integrated group reporting exercise rather than as a last-minute form-filling task.
Identifying In-Scope Group Entities and the Notification Owner
The company should obtain the latest consolidation list from the ultimate parent entity and identify every constituent entity located in Türkiye. For each entity, the working file should show its jurisdiction, operational status, ownership percentage, tax identification number, consolidation method and Pillar Two classification. The group should then determine whether a global minimum top-up corporate taxpayer exists in Türkiye and which entity will submit the notification. If one entity is appointed to act for others, the complete list of entities covered and the allocation of responsibilities must be formally confirmed.
Collecting and Validating Tax, Accounting and Group Structure Data
Data collection should not rely exclusively on Turkish statutory accounting records. Consolidated financial statements, group reporting packages, ownership records, tax returns and intercompany reconciliations should also be reviewed. Turkish legal names must be matched with the names used in foreign group systems, while addresses and tax identification numbers should be verified against official records. The GIR filing jurisdiction, filing entity classification, return ID and filing date should be supported by written confirmation or electronic filing evidence received from the ultimate parent entity.
How Should the Turkish Company Coordinate With the Foreign Ultimate Parent Entity?
The Turkish company should send a standardised information request that corresponds directly to the notification fields. The request should cover the MNE group’s full name, the ultimate parent entity’s legal name and address, the complete list of Turkish constituent entities, the GIR filing entity’s role, the filing jurisdiction, return ID, submission date and authorised contact person. Every response should also identify the fiscal year concerned and the individual who approved the information.
The coordination calendar must be aligned with the foreign GIR preparation schedule because the final return ID and filing date may not become available until submission is completed. Draft data and final filing data should therefore be clearly separated and version-controlled. If the group experienced a merger, acquisition, disposal or legal name change, legal and consolidation teams should participate in the review. The approved dataset should be preserved as a controlled file rather than documented only through fragmented email correspondence.
How Should Internal Responsibilities Be Allocated for the Notification?
The tax team should assess the legal scope and entity classifications, while accounting and financial reporting teams provide consolidation and reporting data. The legal or corporate secretarial team should validate legal names, registered addresses, ownership relationships and corporate changes during the period. Information technology personnel may manage electronic filing access and data security, while an authorised executive should approve the final submission. Assigning the entire process to one department may prevent effective comparison of information held in separate systems.
The preparer, reviewer and approver roles should be clearly separated. Each form field can be accompanied by its source document, responsible person and most recent validation date. A single contact person should communicate with the foreign group headquarters to prevent contradictory data requests. After submission, the filing receipt, final form, supporting workbook, group confirmations and related correspondence should be stored in a restricted-access archive for the applicable statutory retention period.
When and How Is the Notification Form Submitted?
Under the general framework, the global minimum top-up corporate tax return and its accompanying information return are filed by the end of the fifteenth month following the month in which the fiscal year closes. An eighteen-month period applied to the initial 2024 fiscal year. For calendar-year taxpayers, the first-year filing and payment deadline was ultimately extended to 31 July 2026. Companies should check the Turkish Revenue Administration’s current filing calendar for any period-specific extension or procedural announcement.
The form is completed electronically through the New e-Return System during the applicable filing period. Companies are not expected to treat the electronic screen as their primary preparation file. A separate controlled workbook should be completed and approved before the global minimum tax notification is entered into the system. Following submission, the receipt, date and time record, attachments and final dataset should be archived. If an error is subsequently identified, the correction process should follow the current system instructions and official guidance.
What Are the Most Common Mistakes When Preparing the Notification Form?
Common errors include testing the consolidated revenue threshold only for the current year, excluding certain Turkish constituent entities and incorrectly determining the status of the notifying entity. Other recurring issues include using an outdated legal name, entering an incorrect tax identification number, reporting an incomplete ultimate parent address or failing to list all Turkish entities covered by a group-level notification. These mistakes can undermine the completeness of the filing even where no top-up tax is payable.
More serious inconsistencies may arise when the foreign GIR filing jurisdiction, filing entity or return ID is entered without supporting evidence. Assuming that a jurisdiction can exchange GIR information solely because it signed the GIR MCAA can lead to an incorrect assessment of additional reporting requirements. Different reporting periods or entity classifications across the tax return, information return and notification form may also trigger questions from the tax authority. An independent second-level review should therefore be completed before electronic submission.
Which Checks Should Be Completed Before Submitting the Notification?
The first control layer should reconfirm the consolidated revenue threshold, MNE group status and full population of Turkish constituent entities. The second should compare legal names, tax identification numbers, tax offices, jurisdiction codes and registered addresses with official records. The third should determine whether the group has a Turkish global minimum top-up corporate taxpayer and verify which notification sections must consequently be completed.
The final review should cover GIR filing information and any supplementary group reporting requirement. The return ID, filing date, filing entity’s role and contact-person details should be matched with evidence received from the foreign headquarters. All Turkish entities included in the notification must be checked against the consolidation list, and an authorised person should approve the final version. After filing, the submission document should be opened to confirm that it is complete and readable before being archived with its supporting records.
How Does STB CPA Turkey Support the Global Minimum Tax Notification Process?
STB CPA Turkey can support companies with the MNE group scope assessment, classification of Turkish constituent entities and selection of the entity responsible for submitting the notification. Form fields can be compared with organisation charts, trade registry records and tax information to identify missing or contradictory data. Support may also cover preparation of the information request sent to the ultimate parent entity and reconciliation of foreign GIR filing details with the Turkish notification.
Relevant tax audit and advisory services and accounting and financial reporting services can be coordinated to review consistency among the notification form, information return and underlying financial data. Pre-submission controls, organisation of supporting documents and creation of a standard reporting file for subsequent fiscal years can help companies manage their Pillar Two reporting obligations through a more traceable and sustainable process.
