Country-by-Country Report (CbCR) notification

What the notification is

The Turkish name is Çok Uluslu İşletmeler İçin Ülke Bazlı Raporlamaya İlişkin Bildirim Formu: in plain terms, the CbCR notification form. It is not the Country-by-Country Report itself. It tells the Turkish Revenue Administration (GİB) which group entity files the CbC report and in which country, states the group’s consolidated revenue for the previous year, and lists every company the group has in Türkiye, with trade names exactly as published in the Trade Registry Gazette. Everything on the form must be in Turkish.

The form is part of Türkiye’s transfer pricing documentation rules: Presidential Decision 2151 and the Transfer Pricing General Communiqué, as amended by Serial Nos. 4 and 5. Hong Kong finance teams will recognise the idea, because Hong Kong entities file their own CbC notification within three months of the year-end. The Turkish notification is due by the end of the sixth month after the year-end and is filed every year.

One detail matters for the threshold test. GİB’s 2025 explanations count not only sales but also other income from main operations and income from investing activities, where the consolidated statements show them separately.

Deadline and filing

The notification is due by the end of the sixth month after the group’s fiscal year ends. For calendar-year groups that is 30 June: the 2025 notification was due on 30 June 2026, and the 2026 notification is due on 30 June 2027. For other fiscal years the date shifts with the group’s year-end; if your group closes on another date, such as 31 March, we confirm the exact deadline with you before filing.

The form can only be filed electronically through the Digital Tax Office; paper is not accepted. Mistakes can be corrected until the end of the following month (31 July for calendar-year groups); a later correction can be penalised. If the previous year’s consolidated statements are not ready in time, the group can inform GİB and apply for extra time. If a local filing of the 2025 CbC report turns out to be needed, it is due by 31 December 2026; see our year-end 2026 checklist.

What the USD 750 covers

The fee covers three things: checking whether your group is in scope for the year, preparing the notification form and filing it through the Digital Tax Office, and giving you evidence of the filing.

Two pieces of work are not included and are quoted separately: a local filing of the CbC report itself in Türkiye (an XML file submitted through GİB’s BTRANS system), if it becomes necessary, and transfer pricing documentation. Pillar Two calculations and the GloBE information return are also separate work, quoted on request.

How it connects to the global minimum tax

Law 7524 introduced Türkiye’s global minimum tax (Pillar Two): a 15% minimum rate, with the domestic top-up tax and the income inclusion rule applying from 2024 and the undertaxed profits rule from 1 January 2025. It uses the same €750 million figure but measures it differently: the threshold must be exceeded in at least two of the four preceding years. A group can therefore be in scope of one regime and not the other in the same year.

The two regimes meet in the transitional CbCR safe harbour. If a country’s figures in a qualified CbC report pass one of three tests (de minimis, a simplified effective tax rate of at least 17% for 2026, or routine profits), the top-up tax for that country is treated as zero. Under Turkish law as of October 2026, the safe harbour covers fiscal years beginning on or before 31 December 2026, and a group that does not use it for a country in one year cannot use it there in later years. Accurate CbC data therefore matters beyond this filing; our insight on the global minimum tax explains more.

The 2026 global minimum tax notification is a different filing, with its own form, menu and deadline. See the global minimum tax notification, also USD 750.