Turkiye published, on 26 December 2025, the final version of the General Communiqué on the implementation of amendments to Corporation Tax Law No. 5520, introducing Local and Global Minimum Top-up Corporation Tax. The Communiqué provides detailed guidance on the application of Organisation for Economic Co-operation and Development (OECD) Pillar Two rules in Turkiye.

Background

With Law No. 7524 (the Law) published in the Official Gazette dated 2 August 2024, Turkiye enacted Pillar Two legislation, in alignment with the OECD Base Erosion and Profit Shifting (BEPS) 2.0 and Pillar Two rules (for details, see EY Global Tax Alert, Turkiye enacts and publishes amendments to various tax laws for corporations and individuals, including Pillar Two legislation, dated 5 August 2024).

Subsequently, on 3 October 2025, the Turkish Revenue Administration published a Draft General Communiqué on the Local and Global Minimum Top-up Corporation Tax (Pillar Two) and invited stakeholders to submit comments, suggestions or proposed changes by 27 October 2025 (see EY Global Tax Alert, Turkiye issues Draft General Communiqué on Local and Global Minimum Top-up Corporation Tax (Pillar Two), dated 3 October 2024). Following this consultation process, the final version of the General Communiqué was published on the 26 December 2025.

General Communiqué on Local and Global Minimum Top-up Corporation Tax

The General Communiqué details the application of the Local and Global Minimum Top-up Corporation Tax under the OECD Pillar Two rules framework. In particular:

• The rules apply to MNE groups with consolidated revenue ≥ €750m in at least two of the four fiscal years preceding the reporting year.
• A 15% minimum effective tax is ensured through local minimum top-up corporation tax (Qualified Domestic Minimum Tax or QDMTT) in Turkiye and the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) for low-taxed constituent entities abroad.
• QDMTT and the IIR apply to fiscal years starting on or after 1 January 2024, and the UTPR applies to fiscal years starting on or after 1 January 2025.

In this regard, a Global Anti-Base Erosion (GloBE) Information Return will be required, on a one-per-group basis, with local filing obligations in Turkiye in defined cases. As a general rule, Ultimate Parent Entities (UPEs) are required to file the GloBE Information Return (Küresel ATV Bilgi Beyannamesi). However, if another entity designated by the UPE or the group submits this return, the obligation for other entities is eliminated.

Implications

Affected entities should review the Communiqué as the finalized rules will impact compliance obligations and tax considerations for affected MNE groups with fiscal years beginning on or after 1 January 2024.

Note that Turkiye has extended the filing deadline, and associated payment deadline, for the QDMTT return relating to 2024 for taxpayers whose fiscal year is the calendar year. Both deadlines, previously set for 31 December 2025, have been postponed to 15 January 2026. (see EY Global Tax Alert, Turkiye extends Qualified Domestic Minimum Top-Up Tax filing and payment deadlines and releases QDMTT return format for testing, dated 2 December 2025.)