Türkiye applies the OECD global minimum tax (Pillar Two) to large multinational groups. On 11 July 2026, Presidential Decision 11511 (Official Gazette No. 33307) published the lists of jurisdictions whose rules Türkiye treats as qualified. Hong Kong is on all three lists. Mainland China is on none. For the Turkish company of a large Chinese group, that difference shapes what has to be filed in Türkiye.
This article is general information for finance teams, not tax advice.
Two minimum taxes: keep them apart
Law 7524 (Official Gazette 2 August 2024, No. 32620) added two separate regimes to the Corporate Tax Law:
| Domestic minimum corporate tax | Global minimum tax (Pillar Two) | |
|---|---|---|
| Rate | 10% | 15% |
| Who | All companies, except in their first three fiscal periods | Only groups above the €750 million threshold |
| Base | Corporate income before deductions and exemptions | Effective tax rate per jurisdiction under the GloBE rules |
| From | 2025 | 2024 for the domestic top-up tax (QDMTT) and income inclusion rule (IIR); 2025 for the undertaxed profits rule (UTPR) |
| Filed | In the provisional and annual corporate tax returns | Separate returns and forms |
A group is in scope of Pillar Two if the ultimate parent’s consolidated revenue exceeded the Turkish-lira equivalent of €750 million in at least two of the four preceding fiscal years. The detailed rules are in the implementation communiqué of 26 December 2025. A smaller Chinese- or Hong Kong-owned Turkish company is outside Pillar Two, but can still owe the 10% domestic minimum tax from its fourth fiscal period.
Decision 11511: Hong Kong yes, mainland China no
The Decision applies to fiscal years beginning on or after 1 January 2024 and sets three lists:
- jurisdictions eligible for the QDMTT safe harbour;
- jurisdictions with a qualified domestic minimum top-up tax;
- jurisdictions with a qualified income inclusion rule.
“Hong Kong (China)” and Türkiye appear on all three. Mainland China appears on none. There is no UTPR list.
Information exchange follows the same pattern. Türkiye (20 April 2026) and Hong Kong (21 April 2026) have signed the multilateral agreement for exchanging GloBE information returns (GIR); Türkiye approved it by Decision 11396. On the OECD list of 1 October 2026, mainland China is not a signatory.
If the parent is in Hong Kong
- Hong Kong applies its own minimum top-up tax and an IIR to fiscal years beginning on or after 1 January 2025. Its UTPR has not started.
- The Turkish company remains liable for Türkiye’s domestic top-up tax if Turkish profits are taxed below 15%.
- The Turkish UTPR is aimed at groups to which no qualified IIR applies. As we read the law, it should not reach a group whose Hong Kong parent applies its listed IIR.
- If the group files its GIR in Hong Kong, a signatory jurisdiction, the Turkish company refers to that filing in its notification form. GİB has said a GIR filed in a signatory jurisdiction is not filed again in Türkiye.
If the parent is in mainland China
- Turkish companies of groups whose parent is outside Türkiye and to which no qualified IIR applies fall within the Turkish UTPR from 2025. GİB’s guidance so far covers fiscal year 2024; how these companies report under the UTPR for 2025 has not been announced.
- A transitional safe harbour treats UTPR top-up tax as zero where the parent jurisdiction’s corporate tax rate is at least 20%. Mainland China’s rate is 25%, but this safe harbour covers only fiscal years beginning on or before 31 December 2025 and ending by 31 December 2026, in practice calendar 2025. From 2026, the CbCR safe harbour (below) or the de minimis test may still bring the figure to zero.
- If the Turkish company holds the group’s subsidiaries in other countries, it is itself an intermediate parent liable for the IIR. It registers for the global top-up tax (tax type 0064) and files the global return; a notification alone is not enough.
- Unless the GIR is filed in a signatory jurisdiction, such as Hong Kong, the Turkish company also completes GİB’s General Information Form on the group.
What a Turkish subsidiary may have to file
| Filing | Who | When |
|---|---|---|
| Domestic top-up tax return | Every Turkish entity of an in-scope group; one entity can file and pay for all, the others remain jointly liable | 12th month after year-end: 1–31 December 2026 for calendar 2025, even if no tax is due |
| Pillar Two notification form | Turkish entities that are not the ultimate, intermediate or partially-owned parent | Digital Tax Office; the period for the 2025 form has not been announced |
| Global top-up tax return | Turkish parent entities registered for tax type 0064 | 15th month after year-end: by 31 March 2027 for calendar 2025 (18th month for an entity’s first return) |
| CbCR notification | Turkish entities of groups above the CbCR threshold | 6th month after year-end: 30 June 2027 for calendar 2026 |
For 2024, GİB extended the domestic return deadline into January 2026; we have seen no extension for the 2025 return as of 16 October 2026. A de minimis election can reduce the Turkish top-up tax to zero where average Turkish revenue is below €10 million and average profit below €1 million.
Two notification forms, not one
The CbCR notification is a transfer pricing filing under Presidential Decision 2151, due by the end of the sixth month after the year-end (30 June for calendar-year groups). The test is the previous year’s consolidated revenue of €750 million or more; a foreign parent’s own threshold applies instead: more than RMB 5.5 billion for mainland China, at least HK$6.8 billion for Hong Kong.
The Pillar Two notification form opened in the “Bildirimlerim” menu of the Digital Tax Office on 1 June 2026. GİB kept it open after the 2024 return period so that GIR details can be added later. It has not yet announced the filing period for the 2025 form, and the penalty position for this form is not settled.
Because the €750 million test is measured differently, a group can be in scope of one filing and not the other.
The CbCR safe harbour ends with 2026 in Türkiye
If a jurisdiction passes one test using a qualified country-by-country report, its top-up tax is treated as zero: de minimis (revenue below €10 million and profit before tax below €1 million), a simplified effective tax rate of at least 15% for 2024, 16% for 2025 and 17% for 2026, or a routine-profits test. Under Turkish law it covers fiscal years beginning on or before 31 December 2026 and ending no later than 30 June 2028. Once a group skips it for a jurisdiction, it cannot use it there again.
The OECD agreed in January 2026 to extend this safe harbour by one year, but Türkiye had not adopted that extension as of 16 October 2026. For Turkish purposes, plan on it ending with fiscal year 2026.
Incentives can bring the Turkish rate below 15%
Reduced corporate tax rates under investment incentive certificates, the 12.5% rate from 2027 on manufacturing profits of companies with an industrial registry certificate, and exemptions such as free zones all lower the Turkish effective rate. The rules of the domestic 10% minimum tax shield most of these incentives (for incentive certificates, only those obtained before 2 August 2024); the GloBE rules do not. For an in-scope group, the result can be Turkish domestic top-up tax, so model it before you apply for investment incentives.
What this means for you
- Check the two-of-four-years Pillar Two test, and separately the CbCR threshold.
- Establish the Turkish company’s role: ordinary subsidiary (notification) or intermediate parent (registration and global return).
- Put 1–31 December 2026 in the calendar for the 2025 domestic top-up tax return, even if the result is zero.
- Agree with group tax where the GIR is filed.
We file both notifications, USD 750 each: the global minimum tax notification and the CbCR notification. Each fee covers the scope check, the form and evidence of filing (for the global minimum tax notification, also GİB’s General Information Form where it is required); top-up tax returns, tax type 0064 registration, calculations, a local CbC report and transfer pricing documentation are quoted separately. See also our year-end 2026 checklist. You can write to us in Chinese or English: WeChat ID etitax or info@etitax.com.
