Who needs it
- Turkish subsidiaries of mainland Chinese or Hong Kong groups whose consolidated revenue exceeded the Turkish-lira equivalent of €750 million in at least two of the four preceding fiscal years
- Turkish companies that are not the group's ultimate, intermediate or partially-owned parent entity
- Groups that use a Turkish company to hold subsidiaries in other countries: such a company may be liable for the top-up tax itself, so we check this first
- Finance teams that need a clear answer for Türkiye: notification only, or registration and returns as well
What we do
- Scope check: whether the group meets the two-out-of-four-years test, and whether your Turkish company files the notification or is itself a global top-up tax taxpayer
- Collection of the group, ultimate parent and Turkish-entity data, and of the information on where the GloBE information return is filed
- Preparation of the notification form, including GİB's General Information Form (Genel Bilgiler Formu) where it is required, and electronic filing through the Digital Tax Office
- Evidence of the filing: a PDF of the filed form for your group's records
What the form is
The Turkish name is Küresel Asgari Tamamlayıcı Kurumlar Vergisine İlişkin Bildirim Formu: the global minimum tax (Pillar Two) notification. Law 7524 added a new part to the Corporate Tax Law, introducing the local and global minimum top-up corporation tax. It applies a 15% minimum rate to groups whose ultimate parent’s consolidated revenue exceeded the Turkish-lira equivalent of €750 million in at least two of the four preceding fiscal years. The domestic top-up tax and the income inclusion rule apply from 2024, the undertaxed profits rule from 1 January 2025.
GİB published draft forms on 8 April 2026 and opened this notification in the “Bildirimlerim” (My Notifications) menu of the Digital Tax Office on 1 June 2026. Based on the draft, the form asks for the filing company, the group and ultimate parent details, the group’s other Turkish entities, whether the group has a Turkish entity liable for the global top-up tax, and where the GloBE information return (GIR) is filed: in a country that has signed the GIR exchange agreement (including Türkiye), in a country that has not, or not at all. In the last two cases GİB also asks for a General Information Form on the group. The live form may differ slightly from the draft.
Who files, and who files something else
On 16 June 2026 GİB confirmed that Turkish entities which are not the group’s ultimate, intermediate or partially-owned parent file this notification. That is the usual position of a Turkish subsidiary of a mainland or Hong Kong group. These companies do not register for the global top-up tax (tax type 0064) and do not file the global return.
A Turkish parent entity that is liable for the global top-up tax works the other way round: it registers for tax type 0064, files the global return and, where required, the information return, and does not file this notification. One case needs care for mainland groups. If a Turkish company holds the group’s subsidiaries in other countries and the ultimate parent’s country does not apply a qualified income inclusion rule, the Turkish company is itself liable as an intermediate parent. A notification alone is then not enough.
For an in-scope group, Turkish incentives and reduced rates can bring the Turkish effective tax rate below 15%, which is when Türkiye’s domestic top-up tax may arise. If you are planning an investment incentive application, it is worth looking at this early.
Deadline and penalty: what is known
For the 2024 fiscal year, GİB asked for the notification within the global return period, then ending on 30 June 2026, and kept the form open afterwards so that the GIR fields can be completed once the GIR has been filed in Türkiye or abroad. The return deadline was later extended to 31 July 2026; the extension circular does not mention the notification.
GİB has not yet announced the period for the 2025 notification. Under the law, the global return for calendar-year 2025 is due by 31 March 2027 (later for a group filing for the first time); whether the notification will follow the same date is not confirmed.
The penalty position is not settled either (see the FAQ below).
What the USD 750 covers
The fee covers the scope check, preparation and filing of the notification form, GİB’s General Information Form on the group where it is required, and evidence of filing. It does not cover the local or global top-up tax returns, registration for tax type 0064, top-up tax calculations or the GloBE information return itself; these are quoted separately, on request.
If your group is also above the CbCR threshold, the Turkish company has a second annual filing: the CbCR notification, with its own form and a 30 June deadline for calendar-year groups. Our insight on the global minimum tax explains how the rules affect mainland and Hong Kong groups.
How it works
- 01
Scope check
We apply the €750 million two-of-four-years test to your consolidated figures.
- 02
Role check
We establish whether the Turkish company files the notification, or must register for the global top-up tax and file the return instead.
- 03
Data collection
Your group finance team completes our checklist, in Chinese or English; we enter the data in the Turkish form.
- 04
Filing
We file the notification through the Digital Tax Office.
- 05
Evidence
You receive the PDF of the filed form.
What you provide
- A group structure chart showing the ultimate parent, any intermediate holding companies and every Turkish entity
- The ultimate parent's consolidated revenue for the four fiscal years before the year concerned
- Name, country, address and tax number of the ultimate parent entity
- Where and by which entity the group's GloBE information return is, or will be, filed
- If the General Information Form is required (GIR filed in a non-signatory country or not filed): the group-level figures prepared by your Pillar Two advisers (ownership structure, effective tax rate ranges, safe harbour positions)
Frequently asked questions
Is this the same as the CbCR notification?
No. The CbCR notification is a transfer pricing filing that has existed since 2020 and is due by the end of the sixth month after the year-end. The global minimum tax notification is a Pillar Two filing introduced in 2026, with its own form, menu and deadline. A group can be in scope of one and not the other, because the €750 million threshold is measured differently.
Our parent is in mainland China. What does that change?
Mainland China is not on any of Türkiye's three lists of qualified Pillar Two rules (Presidential Decision 11511) and has not signed the multilateral agreement for exchanging GloBE information returns. Unless the group files its GloBE information return in a signatory jurisdiction, the Turkish company will report that it was filed in a non-signatory country or not filed, and complete the General Information Form, which is included in our fee. If the Turkish company holds the group's subsidiaries in other countries, it may itself be liable as an intermediate parent. GİB's 2026 guidance covers the 2024 fiscal year; how these Turkish companies report under the undertaxed profits rule from 2025 has not yet been announced.
Our parent is in Hong Kong. Is it simpler?
Hong Kong applies its own minimum top-up tax (HKMTT) and income inclusion rule to fiscal years beginning on or after 1 January 2025, is on all three Turkish lists, and signed the GloBE information exchange agreement on 21 April 2026 (Türkiye signed on 20 April 2026). If the group's information return is filed in Hong Kong, the Turkish company can refer to it, provided the exchange works in practice. The notification itself is still required.
What is the penalty for not filing?
Neither the Pillar Two articles of the Corporate Tax Law nor the implementing communiqué contain a penalty specific to this form, and GİB has not published an amount. This does not mean there is no risk: general Tax Procedure Law penalties may be relevant, but how they apply to this form has not been confirmed, so we do not quote a figure. We treat the form as mandatory and file it on time.
Do we have to file anything if no top-up tax is due?
Yes. The notification is an information filing, not a tax payment. In addition, every Turkish entity of an in-scope group falls under Türkiye's domestic top-up tax, and that return is filed even when no tax is due: for calendar-year 2025, between 1 and 31 December 2026. That return is not part of this fee and is quoted separately.
Our group is much smaller. Does any minimum tax apply to us?
Not the global minimum tax. But Türkiye's 10% domestic minimum corporate tax applies to all companies from 2025, with new companies exempt for their first three fiscal periods. It is handled in the corporate tax return as part of our bookkeeping and tax filing service.
Source
- Law No. 7524 (Corporate Tax Law Part Five, additional articles 1–13), Official Gazette 2 August 2024, No. 32620
- Local and Global Minimum Top-up Corporation Tax Implementation General Communiqué, Official Gazette 26 December 2025, No. 33119
- Presidential Decision 11511 (lists of qualified rules), Official Gazette 11 July 2026, No. 33307
- Official Gazette 6 June 2026, No. 33272 (Presidential Decision 11396 approving the GIR-MCAA)
- GİB Digital Tax Office announcements (8 April, 1 June, 16 June and 22 July 2026)
- GİB Tax Procedure Law Circular 203 (extension of the 2024 global return)
- OECD: signatories of the GIR Multilateral Competent Authority Agreement
- Inland Revenue Department, Hong Kong: BEPS 2.0 and the global minimum tax