In our assessment, about half of inbound structures confuse two different mechanisms: stopaj, withholding tax “on the way out”, and annual kurumlar vergisi, KV, corporate income tax. For a dar mükellef, a limited taxpayer, meaning a foreign legal entity without its centre in Türkiye, these are not the same thing.
When withholding tax can be final
Without an işyeri, a permanent place of business, and without a daimi temsilci, a permanent or dependent representative, Turkish tax on many types of income is collected at source. For those payments, stopaj is often final: a separate annual corporate tax return is usually not carried forward.
When annual corporate tax appears
If there is a fixed place of business or a dependent agent who regularly concludes deals on your behalf, the commercial profit becomes Turkish-source business profit. In that case, an annual return becomes mandatory.
- The standard rate is the same as for local companies: 25% KV.
- For banks and parts of the financial sector, the rate is 30%.
- From 2025, the same base may also be subject to minimum corporate tax: 10% of profit before certain incentives, if the company is within the filing perimeter.
The calendar if a return is required
The annual period is your hesap dönemi, accounting or financial year. If it is the calendar year, the rule we are reviewing points to a filing window of 1–25 April. In practice, the tax administration has more than once moved the deadline to the last day of the fourth month, meaning 30 April. If you have a special financial year, count the same four-month logic from the period end.
If the company is leaving Türkiye, the return is closed 15 days before departure, not “later from the airport”.
Payment under the annual return is due by the end of the filing month. Under an özel beyanname, a special return, payment is due in the same period as the filing itself.
The 15-day special return
If Turkish income is not “business through a PE / işyeri” but falls into diğer kazanç ve irat, other income and gains, the trigger is the date the income is received, not the year. This can include a sale of real estate, rights, a one-off transaction, a wound-down business and similar items. The period is 15 days.
Where to file depends on the income type:
- for real estate — in the province where the asset is located;
- for movable assets and rights — where the transaction was closed in Türkiye;
- for transport — where the cargo or passenger was loaded.
An exception to this 15-day track is consideration for the sale or assignment of certain intangible rights: telif, imtiyaz, ihtira, marka, ticaret unvanı, meaning copyright, concession or privilege, patent, trademark and trade name. This block specifically carves them out.
Tax for a dar mükellef is attached to the Turkish müdür or temsilci, the manager or representative. If there is none, it attaches to the person who enabled the foreign taxpayer to receive the income. For mail sent to the tax office, tarh, the assessment, is not made on the mailing date but within three days after receipt.
Where we usually cut the risk
A contract with a local “representative”, a warehouse, a long construction project, a person with signing authority, regular services “from Istanbul under a foreign brand” — these are not cosmetic details. They decide whether you remain in final stopaj treatment or are already in annual KV, e-Beyanname, electronic filing, and quarterly geçici vergi, advance or provisional tax.
A double tax treaty can narrow PE and withholding exposure, but only with a certificate of residence and proper payer discipline. Without the document, the Turkish side withholds under domestic rates.
I would not run a model of “we work from abroad, only people are in Türkiye” without a written PE map. The filing calendar is secondary. First answer whether you have an işyeri or daimi temsilci here.