Annual Income Tax Return in Turkey for Employees (2024–2025 Expat Guide)
Annual Income Tax Return in Turkey for Employees (2024–2025 Expat Guide)
Annual Income Tax Return in Turkey for Employees (2024–2025 Expat Guide)
If you are an expat working in Turkey on payroll, you may assume that all of your income tax obligations are already fulfilled through monthly withholding (“stopaj”). For many employees this is correct – but not for everyone.
For 2025, critical thresholds for annual income tax returns on employment income have been updated. If your Turkish-source salary or board fees cross these limits, you must file a personal annual income tax return – even though your employer has already withheld tax.
This guide explains, in clear terms for expats:
When a salary earner must file an annual return in Turkey
How the 2024 and 2025 thresholds work
What happens if you work for more than one employer or change jobs mid-year
Practical examples and structuring tips for group companies
What you can do if you missed a past-year return
1. Why this has become a hot topic
Recently, the Turkish Revenue Administration has begun to actively identify employees who should have filed annual returns but did not. Thanks to:
Turkish ID numbers
Social security (SGK) records
Electronic employer payroll filings
it is extremely easy for the tax office to detect employees whose total salary exceeds the thresholds.
Until now, the tax office largely waited for people to correct themselves “voluntarily”. As year-end approaches, it has reportedly started to send warning and invitation letters to those who appear to have a filing obligation.
For high-paid expats, senior managers, and employees receiving board fees (“huzur hakkı”) from group companies, this is a real risk area.
2. Legal background – in plain English
The rules are mainly set out in:
Article 86 of the Turkish Income Tax Law (Gelir Vergisi Kanunu – GVK)
Income Tax General Communiqué No. 311, which clarifies how these rules are applied in practice
To keep this practical, we will focus only on resident individuals whose employment income has already been taxed by withholding in Turkey and look at three key situations:
Salary from a single employer
Salary from more than one employer (including job changes)
Situations where the overall salary total exceeds a global threshold, even if the first two tests are not triggered
We will also distinguish between the 2024 and 2025 parameters, because audits can cover past years.
3. Key thresholds for 2024 and 2025
3.1. Single employer – high salary
If you receive employment income from only one employer in a calendar year and your annual gross salary:
Does not exceed 3,000,000 TL for 2024, and
Does not exceed 4,300,000 TL for 2025
then you are not required to file an annual income tax return for your salary income.
If you exceed these thresholds in a given year, you must file an annual return, and your full salary from that employer becomes subject to the progressive tax tariff via the return.
3.2. More than one employer – second (and later) employers
If, in the same calendar year, you receive salary or similar payments (e.g. board fees) from more than one employer, you must look at the total gross income from the second and subsequent employers.
If the sum of these “additional” salaries:
Exceeds 230,000 TL for 2024, or
Exceeds 330,000 TL for 2025
then you must file an annual return, and all of your salary income from all employers (including the first one) is included in the tax return.
Two important points for expats:
The “first employer” is your choice
You can designate whichever employer you prefer as your first employer.
Naturally, taxpayers usually choose the employer that pays the highest salary as “first”, because those amounts are excluded from the “additional salary” calculation.
“More than one employer” includes job changes
It does not only mean having multiple simultaneous jobs.
If you leave Employer A in April and start with Employer B in July, you already have more than one employer for that year.
3.3. Global salary total threshold
There is a third and often overlooked rule:
Even if you do not fall into the above two categories, if the total of all your gross salary income:
Exceeds 3,000,000 TL for 2024 or
Exceeds 4,300,000 TL for 2025
then you must file an annual return, and again all of your salary income will be declared.
This rule captures high-income individuals whose second-employer amounts may be modest, but whose total salary package is large.
4. A practical example (General Manager with board fees)
Imagine the following 2025 scenario:
You are a General Manager of a Turkish joint stock company (AŞ)
You receive 4,000,000 TL gross salary from your main employer
You also receive 320,000 TL gross board fee (“huzur hakkı”) from another group company where you sit on the board
Result:
Total salary-type income = 4,000,000 + 320,000 = 4,320,000 TL
This exceeds the 4,300,000 TL global threshold for 2025
Even if your second-employer income (320,000 TL) is only slightly below the 330,000 TL limit, the global threshold is breached. Therefore, you must file an annual income tax return and declare all 4,320,000 TL of income.
5. What counts as “more than one employer”?
This definition is broader than many expats expect. “More than one employer” covers:
Having two or more payroll relationships at the same time (e.g., employed full-time and also receiving fees from another company)
Changing jobs within the year:
- Example: You leave Company X in April and start at Company Y in July. Even if you are never double-paid in the same month, you still have two employers in that calendar year.
Group / holding structures where you:
Are employed by Company A, and
Receive board fees or management fees from Company B, C, etc.
In all of these cases, the “additional” income (everything except the employer you designate as “first”) counts toward the 230,000 TL / 330,000 TL threshold.
6. Non-withheld salary and special cases
Not all salary-type income is taxed through withholding. For example:
Certain “other salary” categories under Article 64 GVK
Certain exempt incomes
As a general rule, if salary income is not subject to withholding tax, and it is not exempt, then it must be declared via an annual return regardless of the amount.
In other words, the friendly thresholds of 3,000,000 TL / 4,300,000 TL and 230,000 TL / 330,000 TL do not apply to non-withheld salary. That income is always declarable.
7. Structuring within group companies (advanced topic)
In practice, the “multiple employer” problem often arises in group or holding structures:
You are formally employed by Company A
You also sit on the board of Company B, C, etc.
Each company pays you separate salary or board fees
In this case, you may quickly cross the 330,000 TL second-employer threshold or the 4,300,000 TL global threshold.
A commonly used structuring approach is:
Your main employer (Company A) becomes the board member in the other company (Company B) instead of you personally.
Company B pays board fees (“huzur hakkı”) to Company A, usually against an invoice.
Company A adds this amount to its revenue and continues to pay a single salary to you on one payroll.
Consequences:
For you personally, there may no longer be multiple employers or separate board fees, so the risk of crossing the second-employer threshold is reduced.
The board fee becomes a service fee between companies:
It is typically subject to VAT,
But no salary withholding tax is applied on the intercompany payment.
This kind of planning must be aligned with Turkish company law, transfer pricing, and VAT rules, so it should only be implemented with detailed professional advice. But it illustrates that the law aims to tax salary at progressive rates, not necessarily to punish group structures if they are properly organized.
8. Mergers and business transfers – is this “more than one employer”?
Another subtle point concerns mergers or business transfers:
If your company merges into another company or is taken over, and you continue working seamlessly for the successor company,
The original corporate employer’s legal personality continues within the merged or acquiring entity from a tax perspective.
In many such cases, this is treated as a continuation of the same employer, not as “two different employers”. Therefore, it does not automatically trigger the multiple-employer rules or create additional tax risk.
Again, specific transaction documents and legal form matter; a case-by-case review is advisable.
9. Hidden benefit of filing: deductions and allowances
If you are required to file an annual return because of your salary thresholds, there is one positive aspect:
You gain access to certain deductions under Article 89 GVK, for example:
Private health and life insurance premiums for yourself, your spouse, and children
Education and healthcare expenses within statutory limits
These can reduce your taxable income and therefore the final tax burden. For high-income expats with significant private education or medical expenses, this can be financially meaningful.
10. What if you missed a past-year return?
Many employees only realize their filing obligation after seeing media reports or receiving a letter from the tax office.
For 2024 income, employees who have not yet been warned may still use the “remorse” (pişmanlık) mechanism:
Through the Revenue Administration’s online “Hazır Beyan Sistemi” (Pre-filled Return System)
You can mark the “pişmanlık” option when filing the overdue return
This allows you to submit the return without the usual tax penalty, although default interest may still apply
This is often the cleanest way to regularize the situation before a formal audit or assessment.
11. Practical checklist for expats in Turkey
Before the filing season begins (usually March of the following year), expat employees should:
List all employers in the relevant calendar year
- Include job changes and group company board roles.
Obtain annual payroll summaries (bordro / annual certificate)
- From each employer and for each type of salary/board fee.
Check the thresholds for the relevant year:
Single employer: 3,000,000 TL (2024) / 4,300,000 TL (2025)
Second and later employers: 230,000 TL (2024) / 330,000 TL (2025)
Total salary: 3,000,000 TL (2024) / 4,300,000 TL (2025)
Identify any non-withheld salary income
- Consulting fees, director fees, or other amounts that may not have been subject to payroll withholding.
Collect documents for possible deductions
- Private health/life insurance, education, and medical expense invoices.
Review with a Turkish tax adviser
- Especially if you have cross-border income, share plans, RSUs, or other complex arrangements that may interact with Turkish rules.
12. Conclusion and next steps
For many expat employees, Turkey’s PAYE-style withholding system works smoothly and no annual return is required. However, if you:
Earn a high salary from a single employer,
Receive income from more than one employer,
Hold board positions or advisory roles in group companies, or
Have non-withheld salary-type income,
you may have an obligation to file an annual income tax return in Turkey, especially under the updated 2024 and 2025 thresholds.
Given the Revenue Administration’s growing focus on this area and the ease with which salary data can be cross-checked, now is the time to review your position rather than wait for a letter.
If you are an expat employee or executive in Turkey and you are unsure whether you should file a return, the safest course is to:
Have your payslips, contracts, and annual income figures reviewed,
Clarify your filing obligations for both past and upcoming years, and
Implement any required structuring or corrections as early as possible.
This not only minimizes penalty risk but may also allow you to benefit from available deductions, ensuring that you pay the correct amount of tax – no more, no less.
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