Upcoming Turkish QDMTT return deadline – 31 December 2025

On 2 August 2024, 13 articles related to the Global Minimum Top-Up Corporate Tax (Pillar Two) was added to Turkish Corporate Income Tax Law. Accordingly, Turkey implemented the "Income Inclusion Rule" (“IRR”) in 2024 and "Undertaxed Payment Rule" (“UTPR”) in 2025, similar to many OECD member jurisdiction. The Law also included the "Domestic Minimum Top Up Tax" (“DMTT”) applicable for the fiscal years started on or after 1 January 2024, and general explanations regarding the taxation period, declaration, assessment and payment of the DMTT.

The calculation of the Turkish DMTT, to the extent provided for in the Law, is generally aligned with that of the OECD GloBE Model Rules, including e.g., the de minimis exclusion and the Transitional CbCR Safe Harbour rules. Accordingly, the Turkish DMTT is considered to be a Qualified DMTT (“QDMTT”) based on the OECD’s central record (*).

The filing deadline for the Turkish QDMTT return has been set as 31 December 2025. While in the majority of European jurisdictions, the QDMTT returns will be filed on 30 June 2026 for the first implementation year. Türkiye is classified among the “early filing” countries due to its earlier deadline.

Given the early filing timeline compared to other jurisdictions, coupled with the absence of the relevant secondary legislation/ guidance (i.e., the local implementation communiqué) and QDMTT return template, there remain several uncertainties regarding the filing process —particularly regarding the format and content of the QDMTT return, and whether entities that qualify for the Transitional CbCR Safe Harbour, hence do not have QDMTT payable for 2024, will have filing obligation as well (so called “zero return”).

These ambiguities hinder companies from adequately preparing and finalizing their QDMTT compliance processes in a timely manner. Since there is currently no indication of a potential deferral of the filing deadline, it is advisable that companies proactively begin calculating their Turkish QDMTT liabilities in line with the OECD GloBE Model Rules to ensure readiness.

Additional announcements will be made regarding the Turkish QDMTT return and further developments regarding the compliance process, as they are announced.

(*) OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules – Central Record (January 2025), OECD/G20 Inclusive Framework on BEPS, OECD, Paris. Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), Central Record of Legislation with Transitional Qualified Status (Version January 2025)