Possible Local Filing of GIR in Türkiye if GIR MCAA is Not Signed and Automatic Exchange Agreements are not Effective by 30 June 2026

Abstract: If Türkiye does not sign the Global Information Return (“GIR”) MCAA and establish automatic exchange agreements by 30 June 2026, Turkish authorities may require local GIR filings from Turkish entities of large multinational groups. Given time constraints and with a view to minimising compliance burdens, we suggest that Türkiye either utilise voluntary or ad hoc information requests from taxpayers or implement formal local GIR filing requirements to ensure systematic access to group-wide information. Additionally, it is recommended that the deadline for local GIR filing be extended for foreign-headquartered companies to allow taxpayers additional time for compliance.

The Global Information Return (GIR) forms part of the international tax transparency framework under OECD/G20 initiatives. Many countries, including Türkiye, require Ultimate Parent Entities (UPEs) in their jurisdictions to file the 2024 GIR by 30 June 2026. The standard process involves primary GIR filing in the UPE’s jurisdiction, automatic exchange with other relevant jurisdictions, and secondary/local filing only if the automatic exchange could not be achieved.

This approach aligns with existing Country-by-Country Reporting (CbCR) and Pillar Two GloBE returns. Automatic exchange depends on GIR MCAA agreements. Though this is expected to be completed by 30 June 2026, currently, Türkiye has not signed or ratified the GIR MCAA. If neither multilateral nor bilateral agreements are active by that date, automatic exchange with Türkiye won’t be operational. This could result in Türkiye lacking access to GIRs from other jurisdictions, prompting possible local filing requirements.

Türkiye already enforces CbCR rules, requiring local filings when international exchange mechanisms are unavailable or fail. A similar requirement may apply for GIR, imposing extra compliance burdens on foreign and Turkish-headquartered companies. Last-minute legislation could lead to missed deadlines and operational challenges, especially since Türkiye accepts GIR in an e-return template, while other jurisdictions may need XML versions.

Conclusion for Türkiye: Policy and Practical Considerations

If Türkiye does not sign the GIR MCAA and relevant automatic exchange agreements are not in effect by 30 June 2026, it is likely that Turkish authorities will give serious consideration to implementing a local or secondary GIR filing requirement for Turkish entities that are part of large multinational groups.

International practice concerning CbCR and Pillar Two/GloBE Information Returns demonstrates a consistent approach: Primary filing combined with automatic exchange is generally regarded as the optimal model; however, when this model is unavailable, many jurisdictions adopt local filing as a reliable alternative mechanism.

If Türkiye reaches 30 June 2026 without an effective GIR MCAA or bilateral exchange framework, policymakers will be confronted with below choices:

1. Rely on voluntary or ad‑hoc information requests from taxpayers; or
2. Introduce formal local GIR filing requirements to secure systematic access to group‑wide information.
3. Extend the deadline for local GIR filing for foreign headquartered entities to provide extra time to taxpayers for compliance.