Beneficial ownership filing

What the rule requires

Türkiye’s beneficial ownership rules are set out in Tax Procedure Law General Communiqué No. 529 (Official Gazette, 13 July 2021). They follow the transparency standards of the OECD Global Forum and the FATF. A beneficial owner is always a natural person: the individual or individuals who ultimately control a company or have ultimate influence over it. A holding company is never the answer.

The Communiqué applies three tests, in this order:

1. individual shareholders holding more than 25% of the company;
2. if there are none, or if there is doubt that such a shareholder is the real owner, the individuals who ultimately control the company;
3. if no one can be identified under the first two tests, the individuals with the highest executive authority.

A company reports this information with its provisional and annual corporate tax returns. In addition, a new tax registration, or any change in information already reported, must be notified within one month. Filing is electronic only: paper is not accepted, and the filing must be approved in the system by 23:59 on the last day. The company itself, or a licensed Turkish CPA (SMMM) under an intermediary agreement, can file.

Holding chains from Hong Kong and mainland China

When a Turkish company is owned through a holding company, for example in Hong Kong, rather than directly by individuals, the first test finds no individual shareholder in the Turkish company. The work then moves to the second test: we look through each layer to the people at the top and establish who ultimately controls the Turkish company.

Two examples:

• Founder-owned holding. One or more founders own a Hong Kong company, which owns the Turkish company. The founders’ holdings and voting arrangements in the Hong Kong company decide who is reported.
• Larger or listed groups. Where shares are widely held and no individual can be identified as controlling the company, the persons with the highest executive authority are reported.

Every layer needs a document that shows its owners, so start collecting them as soon as the structure is decided: the one-month period does not wait for paperwork from abroad.

Why it matters beyond the tax office

The same question comes up when you open a company bank account: Turkish banks identify beneficial owners as part of their customer checks. Keeping the answers consistent across the tax office, the bank and the trade registry avoids contradictions that would later need explaining.

The Communiqué also requires the company to keep the information for five years from the start of the calendar year after the notification.

What the fee covers

USD 1,250 covers one notification: the first filing for a newly registered company, or a filing after a change. If the information changes again later and a new notification is required, that is a new service with its own fee. If we keep your books under a Basic or Professional package, we also file the provisional and annual corporate tax returns that carry the beneficial owner information. Setting up a new company? The one-month period starts with tax registration, so plan this filing together with company formation.