Tax enforcement in Türkiye has shifted from companies to their owners. The share of large taxpayers placed under audit rose from around 11% in previous years to 31.3% in 2026, meaning almost one in three is being examined. Running alongside it is the Second Monitoring and Compliance Programme for High Income Groups: 16,307 individuals under observation and 48.7 billion lira of additional declared tax base. Here is what the system actually examines and how to structure the company-owner link so it does not create exposure.
Scale and structure of the programme
Audit intensity now depends on size: large taxpayers 31.3%, medium 7.3%, small 1.1%. For medium taxpayers the main instrument is the invitation to explain (izaha davet); for small ones, cautionary monitoring.
Individuals in the programme fall into two groups. First: shareholders in Türkiye's 42,000 largest companies whose personal income tax filings do not match the economic indicators identified by risk analysis. Second: individuals with no company shareholding at all, whose lifestyle and spending do not match the taxes they pay.
The results in numbers: personal income tax base up 6.7 billion lira, withholding base at the companies where these individuals are partners up 4.2 billion, and the corporate tax base of those companies up 33.9 billion. Around 7,000 people had never filed a return before and filed for the first time.
What the system cross-checks
The programme is formally not a tax audit. It is a preliminary layer: risk analysis, monitoring and an invitation to voluntary compliance. The letters state that absent reasonable explanation or voluntary correction, the person may be re-assessed for the purposes of a full audit.
Assessed together in one view: company shareholdings, whether dividends were distributed, the individual's income declaration, real estate transactions, vehicle records, bank account movements and credit card spending.
One detail every owner should know: among the risk indicators is the explicit absence of any withholding filed in the owner's name for a 2025 dividend distribution. And bank inflows are not merely totalled, they are classified by payment description: interest, dividends, rent, director's fee (huzur hakkı), salary. The system then compares the implied income and spending level against the tax filings.
The new question: what funds the owner's life
A company can operate for years, earn profit and retain it in the business. That is lawful and commercially normal: investment, working capital, debt reduction, a buffer against risk. But the risk analysis asks a different question: if the company does not distribute profit, what finances the owner's high level of spending?
Where an individual has multi-million property or vehicle transactions, heavy card spending and significant account movements, while declared income is minimal, the system automatically generates a query about the source.
The source may be entirely legitimate: past savings, sale of an asset, inheritance, borrowing, an intra-family transfer, previously taxed income. What matters now is not only that a source exists, but that it can be evidenced.
Is this forcing dividend distribution?
Officially, no: the stated aim is aligning filings with real income, tackling the informal economy and encouraging voluntary compliance. Concluding that "the tax authority now requires dividends" would be legally wrong.
The indirect effect, however, is plain. When the absence of distribution appears in the list of risk indicators, and bank inflows are classified by income type, the logic reads clearly: the state prefers the owner's economic life to be funded through legally defined channels with tax consequences (dividends, salary, director's fee) rather than through unrecorded or unexplained flows out of the company.
What owners should do: the company-owner boundary
The governing rule for the period ahead: the financial boundary between a company and its owner must be managed deliberately. Now exposed not only as accounting technique but as risk-analysis input:
- personal expenses of the owner paid by the company;
- a continuously growing shareholder current account;
- corporate cards used for personal purposes;
- cash taken out of the company without a basis;
- a profitable company alongside an owner with no visible income.
The right answer depends on the case. Sometimes retaining profit is rational, and then the owner needs a separate documented funding source. Sometimes regular dividend distribution makes sense. Sometimes, where genuine management services are provided, a director's fee or salary is appropriate, structured within corporate and tax law. There is no universal answer, but having no answer is itself now a risk.
How to prepare
Check the company-owner link on three points. First: do you personally have an official income source that explains your standard of living, and is it reflected in a filing? Second: how do your bank inflows look by payment description, are dividends, director's fee or salary visible there? Third: can you evidence the source of major expenses and transactions over recent years (savings, an asset sale, inheritance, a documented loan)?
If there is a gap, close it before the letter arrives: at the monitoring stage voluntary correction is available; once the matter moves to audit, the terms are harsher.
If your company is profitable and you personally declare nothing, that gap is already visible to the system. We audit the company-owner link, select the right funding channel and build the supporting documentation. Contact us.