Domestic Minimum Corporate Tax: Rules and Worked Examples
Introduction
In order to broaden the tax base and promote fairness, recent legislative efforts have accelerated the gradual removal of certain exemptions, reliefs and deductions. With Law No. 7524—effective January 1, 2025—the Turkish Corporate Tax Law was amended by adding Article 32/C, titled “Domestic Minimum Corporate Tax,” to scale back the tax advantages granted by exemptions and reliefs deemed no longer effective.
Below, we explain the scope and mechanics of the Domestic Minimum Corporate Tax and share our comments in line with the current draft communiqué.
A. Principles of Implementation
1. General Framework
Under the Corporate Tax Law (Articles 32 and 32/A), a company’s corporate tax is calculated by applying the statutory rate to its net accounting profit (adjusted for non-deductible expenses). The new rule requires that, before applying any exemptions or reliefs, this tax cannot fall below 10 percent of the company’s pre-exemption profit.
Thus, corporate tax is determined in two steps:
Standard Calculation: Compute tax under Articles 32 and 32/A, ignoring the minimum-tax rule.
Minimum-Tax Calculation: Determine the “minimum-tax” base (pre-exemption profit) and calculate 10 percent of that amount.
The higher of these two results is reported as the corporate tax liability.
2. Who Must Pay the Minimum Tax?
All corporate taxpayers subject to Turkish corporate tax—including those who report exempt income or claim reliefs—must comply with the minimum-tax rule. Income‑tax payers are not affected. Foreign-headquartered entities that file a Turkish corporate‑tax return on their Turkish‑source profits also fall within scope.
3. Exemptions from the Minimum‑Tax Rule
The minimum‑tax rule does not apply to:
Entities exempt from corporate tax.
Newly established companies, for their first three fiscal years.
- E.g., a company established in 2025 is exempt for 2025–2027.
Companies taxed on a “revenue basis” under Income Tax Law Art. 113.
Mergers, demergers or conversions do not qualify as “newly established” for this purpose.
4. Detailed Mechanics
The minimum‑tax base is the company’s accounting profit (or loss) plus non‑deductible expenses, before exemptions and reliefs.
If this sum is positive, the minimum‑tax liability is 10 percent of that amount.
Carried‑forward losses remain deductible for standard corporate tax but cannot reduce the minimum‑tax base.
In inflation‑adjustment periods, inflation‑adjusted values are included in the minimum‑tax base.
From the computed minimum tax, the following are deducted (to the extent they reduced tax under Articles 32/6‑8 or 32/A):
2 percent discount for IPO proceeds (min. 20 percent float).
5 percent discount on export profits.
1 percent special rate for manufacturing companies holding a valid Industrial Registry Certificate.
Tax exemptions/reliefs under investment‑incentive certificates issued before August 2, 2024.
Tax paid via withholding or provisional returns is credited against the final minimum‑tax liability.
Also, if a company undergoes liquidation, merger, demerger or transfer, it must calculate the minimum tax for its final return. Some corporate taxpayers holding Income Tax Law Art. 121 relief may also apply that relief to their minimum tax.
5. Exemptions and Reliefs Deductible From the Minimum‑Tax Base
(The following may be subtracted when determining the minimum‑tax base.)
| Law Reference | Description |
| CTL 5/1‑a | Participation exemption |
| CTL 5/1‑ç | Share premium gains exemption |
| CTL 5/1‑d | Portfolio‑management gains of investment funds (excl. real estate) |
| CTL 5/1‑i | Rebate (“risturn”) gains exemption |
| CTL 5/1‑j | Sale‑and‑leaseback gains exemption |
| CTL 5/1‑k | Asset‑leasing gains exemption |
| CTL 10/1‑g | Venture‑capital relief under VUK 325/A |
| CTL 10/1‑h | Protected‑workshop relief (Disability Law 5378) |
| Law 4490 | Gains from Turkish International Ship Registry |
| Law 3218 | Free‑zone gains exemption |
| Law 4691 | Technology‑park gains exemption |
| Law 5746 | R&D and design relief |
| Various | Other reliefs recorded under “Other deductions” on the return |
6. Exemptions and Reliefs Not Deductible From the Minimum‑Tax Base
| Law Reference | Description |
| CTL 5/1‑b | Foreign participation gains exemption |
| CTL 5/1‑c | Foreign share‑sale gains exemption |
| CTL 5/1‑d (real‑estate) | Real‑estate gains of funds |
| CTL 5/1‑e | Real‑estate, share and fund‑sale gains exemption |
| CTL 5/1‑f | Real‑estate gains exemption for indebtedles |
| CTL 5/1‑g | Foreign‑branch gains exemption |
| CTL 5/1‑h | Foreign‑construction/service gains exemption |
| CTL 5/1‑ı | Education/training gains exemption |
| CTL 5/A | Foreign‑fund management company gains exemption |
| CTL 5/B | IP‑rights sale‑gains exemption |
| CTL Tr 14 | FX‑protected deposits gains exemption |
| Former ITL 19, PTL 61, 69 | Investment‑allowance exemption |
| Law 5300 | Licensed‑warehouse gains exemption |
| Law 6650 | Research‑infrastructure exemption |
| Various | Other special exemptions |
| CTL 10/1‑b to 10/1‑i | Sponsorship, donation, cultural, software‑export reliefs |
| Various | Other special law reliefs |
Note: Carried‑forward losses do not reduce the minimum‑tax base and are not deductible from it.
B. Worked Examples
Below are eight illustrative calculations for the 2025 fiscal year. In each case, two figures are compared:
The higher amount is the company’s final corporate‑tax liability.
Example 1: Göztepe A.Ş.
Accounting profit: ₺1,000,000
Non‑deductible expenses: ₺200,000
No exemptions or carried‑forward losses
| Calculation | Corporate Tax | Minimum Tax |
| Tax base | ₺1,200,000 | ₺1,200,000 |
| Rate | 25 % | 10 % |
| Tax due | ₺300,000 | ₺120,000 |
Result: ₺300,000 (standard tax is higher).
Example 2: Bodrum A.Ş.
Accounting loss: ₺1,000,000
Non‑deductible expenses: ₺1,200,000
No exemptions or losses
| Calculation | Corporate Tax | Minimum Tax |
| Tax base | ₺200,000 | ₺200,000 |
| Rate | 25 % | 10 % |
| Tax due | ₺50,000 | ₺20,000 |
Result: ₺50,000 (standard tax is higher).
Example 3: Samsun A.Ş.
Accounting profit: ₺4,000,000
Non‑deductible expenses: ₺800,000
Exemptions:
Participation exemption ₺2,000,000
Share‑sale exemption ₺800,000
Tech‑park exemption ₺500,000
Reliefs:
Carried‑forward losses ₺400,000
| Calculation | Corporate Tax | Minimum Tax |
| Tax base: (a + b – exemptions – reliefs – losses) | ₺800,000 | ₺2,200,000 |
| Rate | 25 % | 10 % |
| Tax due | ₺200,000 | ₺220,000 |
Result: ₺220,000 (minimum tax is higher).
Example 4: Fenerbahçe A.Ş.
Accounting profit: ₺12,500,000
Non‑deductible expenses: ₺500,000
2021 investment‑incentive certificate (₺4,000,000 matrah at 5 %)
Gain on asset transfer: ₺4,000,000 (bank debt transfer)
R&D deduction ₺2,000,000
Investment‑allowance from prior years ₺1,000,000
| Calculation | Corporate Tax | Minimum Tax |
| Tax base after incentives and reliefs | ₺6,000,000 | ₺11,000,000 |
| Tax due (incentive + standard) | ₺700,000 | – |
| Minimum raw tax (10 %) | – | ₺1,100,000 |
| Less unused incentive tax (₺800,000) | – | ₺300,000 (net) |
Result: ₺700,000 (standard tax is higher).
Example 5: Beşiktaş A.Ş. (GYO)
Accounting profit: ₺15,000,000
Property‑income exemption: ₺5,000,000
Carried‑forward losses: ₺5,000,000
Incentive‑certificate matrah: ₺2,000,000 at 5 %
| Calculation | Corporate Tax | Minimum Tax |
| Tax base (post‑exemptions/losses) | ₺5,000,000 | ₺15,000,000 |
| Tax due | ₺850,000 | ₺1,100,000 |
Result: ₺1,100,000 (minimum tax is higher).
Example 6: Galatasaray A.Ş.
Accounting profit: ₺10,000,000
Non‑deductible expenses: ₺1,000,000
Exemptions:
Relief: cash‑capital deduction ₺2,000,000
5 % export‑discount on ₺2,000,000
| Calculation | Corporate Tax | Minimum Tax |
| Tax base (post‑exemptions/relief) | ₺4,000,000 | ₺10,000,000 |
| Tax due | ₺900,000 | ₺900,000 |
Result: ₺900,000 (tie: standard tax applies).
Example 7: Beşiktaş REIT A.Ş.
| Calculation | Corporate Tax | Minimum Tax |
| Tax base (post‑exemptions) | ₺0 | ₺3,000,000 |
| Tax due | ₺0 | ₺300,000 |
Result: ₺300,000 (minimum tax applies).
Example 8: Hatay A.Ş.
Accounting profit: ₺7,000,000
Exemptions:
Foreign‑participation gains ₺1,000,000 (15 % tax paid abroad)
Foreign‑service gains ₺800,000 (50,000 ₺ tax; implies 6.25 % burden)
IP‑sale gains ₺4,000,000
Only the portion of the service gain that did not carry a ≥ 10 % foreign burden (₺300,000) is taxable
| Calculation | Corporate Tax | Minimum Tax |
| Tax base | ₺1,200,000 | ₺5,500,000 |
| Tax due | ₺300,000 | ₺550,000 |
Result: ₺550,000 (minimum tax is higher).
Conclusion
The introduction of the Domestic Minimum Corporate Tax under Law 7524 has added complexity to corporate‑tax calculations. While its aim is to expand the tax base and promote fairness, it creates new cash‑flow and budgeting challenges—particularly for companies currently benefiting from exemptions. We recommend that, instead of temporary fixes, policymakers pursue simplification of the tax code and adopt durable, transparent measures under a unified framework.
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