Turkiye published, on 3 October 2025, a Draft General Communique on the implementation of amendments to Corporation Tax Law No. 5520, introducing Local and Global Minimum Top-Up Corporation Tax. This draft provides the details for applying the Organisation for Economic Co-operation and Development (OECD) Pillar Two rules, along with the template for the Global anti-Base Erosion ( GloBE) Information Return. To support the finalization and publication of the Communique, the Turkish Revenue Administration invites stakeholders to submit comments, suggestions or proposed changes by 27 October 2025.

Background

When Law No. 7524 (the Law) was published in the Official Gazette dated 2 August 2024, Turkiye enacted Pillar Two legislation, in alignment with 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).

Draft General Communique

The Draft General Communique 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.
• Pillar Two rules were legislated in Turkiye in 2024; QDMTT and the IIR apply to fiscal years starting on or after 1 January 2024, and UTPR applies to fiscal years starting on or after 1 January 2025.

In this regard, a GloBE Information Return will be required, generally 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.

The Turkish Revenue Administration continues its work to finalize and publish the Draft General Communiqué on the Local and Global Minimum Top-Up Corporation Tax. Stakeholders should review the current draft and consider sharing comments, proposed changes or contributions by 27 October 2025.