# Pillar Two in Turkey: Global Minimum Tax, QDMTT & Filing Requirements (2026)

# Pillar Two in Turkey: Global Minimum Tax, QDMTT & Filing Requirements (2026)

**If your multinational group has a company in Turkey and consolidated annual revenue of EUR 750 million or more, the Turkish entity may have separate Pillar Two calculation, reporting and filing requirements — even if the group's Pillar Two work is already handled centrally outside Turkey.**

Turkey has implemented the OECD Pillar Two global minimum tax framework, including a **15% minimum effective tax rate**, domestic minimum top-up taxation and global minimum top-up taxation.

For multinational groups with Turkish subsidiaries, the practical question is therefore no longer simply:

**“Does Pillar Two apply in Turkey?”**

The more important questions are:

*   Is our Turkish subsidiary within the scope?
    
*   Does Turkey require a local Pillar Two filing?
    
*   Is a Turkish domestic minimum top-up tax calculation required?
    
*   Can a safe harbour apply?
    
*   If our global adviser performs the central GloBE calculation, who handles the Turkish compliance layer?
    

This guide explains the Turkish Pillar Two framework from a local compliance perspective.

* * *

## Pillar Two Turkey: Quick Answer

For tax directors, CFOs and group finance teams, the Turkish Pillar Two framework can be summarised as follows:

| Issue | Turkey |
| --- | --- |
| Pillar Two implemented? | Yes |
| Revenue threshold | EUR 750 million group consolidated revenue, subject to the applicable tests |
| Minimum effective tax rate | 15% |
| Domestic minimum top-up tax | Yes |
| Income Inclusion Rule (IIR) | Yes |
| Undertaxed Profits Rule (UTPR) | Included in the Turkish framework |
| Turkish Pillar Two filing | Yes |
| First Global Minimum Top-Up Corporate Tax filing | 2024 accounting period |
| 2024 Global Minimum Top-Up Tax deadline | Extended to 31 July 2026 |
| Safe harbour framework | Yes, subject to applicable Turkish rules and designated jurisdictions |

The key point is that the **EUR 750 million threshold is tested at multinational group level**, not by looking only at the turnover of the Turkish subsidiary.

* * *

## Does Pillar Two Apply to a Turkish Subsidiary?

Potentially, yes.

The starting point is whether the Turkish company is part of an in-scope multinational enterprise group.

Consider this simplified structure:

**German Ultimate Parent Entity**

↓

**Turkish Subsidiary**

↓

Other group companies in the Netherlands, Poland and UAE

Assume:

*   Global consolidated revenue: **EUR 1.4 billion**
    
*   Turkish subsidiary revenue: **EUR 8 million**
    

The Turkish subsidiary cannot be excluded from the Pillar Two analysis merely because its standalone revenue is EUR 8 million.

The relevant threshold is determined by reference to the **consolidated revenue of the multinational group**, subject to the detailed scope rules.

This distinction is particularly important for relatively small Turkish subsidiaries of large European, US, Asian and Middle Eastern groups.

* * *

## What Is the EUR 750 Million Pillar Two Threshold?

The EUR 750 million threshold is one of the first scope tests that a multinational group should review.

It does **not** generally mean:

> “Does our Turkish company have EUR 750 million of revenue?”

Instead, the question is:

> **“Is the Turkish entity part of a multinational group whose consolidated revenue meets the EUR 750 million Pillar Two threshold under the applicable testing rules?”**

Accordingly, even a Turkish entity representing a relatively small part of the group's worldwide operations may fall within the Turkish Pillar Two compliance workstream.

Certain entities and structures may be excluded or subject to specific treatment. A scope assessment should therefore precede the actual tax calculation.

* * *

## How Does the 15% Global Minimum Tax Work?

Pillar Two is designed to ensure a minimum level of taxation for in-scope multinational groups on a jurisdictional basis.

A simplified example illustrates the concept:

Pillar Two effective tax rate in a jurisdiction:

**11%**

Minimum rate:

**15%**

Simplified rate differential:

**4 percentage points**

However, this does **not** mean that the top-up tax simply equals 4% of the local accounting profit.

The actual calculation may involve:

*   GloBE income or loss,
    
*   covered taxes,
    
*   deferred tax adjustments,
    
*   jurisdictional blending,
    
*   substance-based income exclusion,
    
*   prior-year adjustments,
    
*   safe harbours, and
    
*   other GloBE-specific adjustments.
    

The Pillar Two effective tax rate is therefore a separate calculation and should not be equated with Turkey's headline corporate income tax rate.

* * *

## Turkey's Corporate Tax Rate Is Above 15%. Why Does Pillar Two Still Matter?

This is one of the most important practical misconceptions.

A Turkish statutory corporate income tax rate above 15% does **not automatically mean**:

> “There is no Pillar Two issue in Turkey.”

Pillar Two uses its own methodology for determining GloBE income and covered taxes.

The outcome may be affected by items such as:

*   tax incentives,
    
*   exemptions,
    
*   tax credits,
    
*   tax losses,
    
*   deferred tax positions,
    
*   permanent differences,
    
*   financial accounting treatment, and
    
*   specific GloBE adjustments.
    

A multinational group should therefore distinguish between:

**Turkish statutory corporate income tax rate**

and

**Pillar Two jurisdictional effective tax rate.**

They are not necessarily the same number.

* * *

## What Is Turkey's Domestic Minimum Top-Up Tax (QDMTT)?

Turkey has introduced a domestic minimum top-up tax mechanism as part of its Pillar Two framework.

Broadly, where the Pillar Two effective tax rate attributable to relevant Turkish operations falls below the minimum level, Turkey may impose a domestic top-up tax, subject to the detailed rules.

From a multinational group's perspective, this matters because the Turkish Pillar Two position should be analysed **locally**, even where the group's overall GloBE calculations are prepared centrally.

A Turkish review may therefore need to consider:

*   Turkish constituent entities,
    
*   Turkish GloBE income,
    
*   covered taxes,
    
*   deferred taxes,
    
*   applicable exclusions,
    
*   substance-based income exclusion,
    
*   safe harbour eligibility, and
    
*   potential domestic top-up tax.
    

* * *

## What Changed in Turkey's Pillar Two Safe Harbour Rules in 2026?

This is now an important part of the Turkish Pillar Two analysis.

In July 2026, Turkey published **Presidential Decision No. 11511** concerning jurisdictions recognised for purposes including qualified domestic minimum top-up tax safe harbour treatment, qualified domestic minimum top-up taxation and qualified IIR treatment.

This means that a 2026 Turkish Pillar Two review should not stop at calculating an effective tax rate.

The group should also determine:

> **Can an available safe harbour simplify or change the Turkish Pillar Two calculation or compliance process?**

Safe harbour eligibility should be tested against the group's facts and the jurisdictions involved rather than assumed automatically.

* * *

## What Is the Global Minimum Top-Up Corporate Tax in Turkey?

Turkey has also implemented the global component of the Pillar Two framework.

This includes rules corresponding to the:

**Income Inclusion Rule (IIR)**

and

**Undertaxed Profits Rule (UTPR).**

Under the IIR, certain parent entities located in Turkey may potentially become liable in respect of low-taxed constituent entities located in other jurisdictions.

Depending on the ownership structure, the relevant Turkish entity may be an:

*   Ultimate Parent Entity (UPE),
    
*   Intermediate Parent Entity, or
    
*   Partially-Owned Parent Entity.
    

For this reason, one of the first documents required in a Turkish Pillar Two assessment is usually the group's **legal ownership and entity structure**.

* * *

## Is There a Pillar Two Tax Return in Turkey?

**Yes.**

This is one of the most important developments for multinational groups.

Turkey has moved from Pillar Two legislation to **actual compliance and filing**.

For the 2024 accounting period, the Turkish Revenue Administration required the filing of the **Global Minimum Top-Up Corporate Tax Return**.

The deadline for the 2024 return and payment was subsequently extended from 30 June 2026 to:

**31 July 2026**

The Turkish tax calendar also included the related **Global Minimum Top-Up Corporate Tax Information Return** for the 2024 period.

This confirms an important point for international tax teams:

> **Pillar Two in Turkey is now an operational local tax compliance requirement, not merely an OECD policy issue.**

* * *

## Does a Foreign-Prepared GloBE Information Return Eliminate Turkish Compliance?

Not necessarily.

This distinction is particularly relevant for multinational groups whose central Pillar Two work is performed by a global tax department or an adviser outside Turkey.

For example:

**German Parent**

Global Pillar Two calculations → prepared in Germany

GloBE data → centrally managed

Turkish subsidiary → local statutory accounting and tax compliance in Turkey

The fact that the group has already completed its global Pillar Two calculations does not, by itself, establish that all Turkish requirements have been satisfied.

The Turkish workstream should separately determine:

1.  Which Turkish entities are in scope?
    
2.  What information must be provided locally?
    
3.  What Turkish returns or notifications are required?
    
4.  Is a Turkish domestic top-up tax calculation required?
    
5.  Does a safe harbour apply?
    
6.  How should the Turkish filing reconcile with the group's global GloBE work?
    

This is where coordination between the **global Pillar Two adviser and the Turkish local tax adviser** becomes particularly important.

* * *

## What Information May Be Needed From the Turkish Subsidiary?

Pillar Two compliance is considerably more data-intensive than a standard Turkish corporate income tax return.

Depending on the group's circumstances, the Turkish workstream may require information concerning:

*   group ownership structure,
    
*   Turkish constituent entities,
    
*   financial accounting data,
    
*   current tax expense,
    
*   deferred tax,
    
*   permanent differences,
    
*   tax incentives and exemptions,
    
*   tax losses,
    
*   intragroup transactions,
    
*   covered taxes,
    
*   GloBE adjustments,
    
*   substance-based income exclusion,
    
*   safe harbour calculations, and
    
*   the group's existing GloBE reporting process.
    

A Turkish subsidiary's finance team should therefore not wait until the filing stage to coordinate with the group's central tax function.

* * *

## Turkey Pillar Two Compliance Checklist

If your group has one or more entities in Turkey, start with these questions:

**1\. Does the group meet the EUR 750 million revenue threshold?**

**2\. Which Turkish companies qualify as constituent entities?**

**3\. Who is the Ultimate Parent Entity and where is it located?**

**4\. Who prepares the group's central Pillar Two/GloBE calculation?**

**5\. Has the Turkish jurisdictional effective tax rate been calculated?**

**6\. Does Turkey's domestic minimum top-up tax need to be considered?**

**7\. Can a safe harbour apply?**

**8\. What Turkish returns, information returns or notifications are required?**

**9\. Have the global Pillar Two calculations been reconciled with Turkish statutory tax data?**

**10\. Who is responsible for the Turkish filing?**

If the answer to the final question is unclear, the group's Turkish Pillar Two compliance process may not yet be complete.

* * *

## We Already Work With a Global Pillar Two Adviser. Do We Need a Turkish Adviser?

A multinational group may already work with a global accounting firm or Pillar Two technology provider.

That does not necessarily remove the need for Turkish local support.

The responsibilities can be complementary.

The global team may manage:

*   group-wide GloBE methodology,
    
*   central calculations,
    
*   global data collection,
    
*   group reporting, and
    
*   overall Pillar Two governance.
    

The Turkish adviser can focus on:

*   Turkish constituent entities,
    
*   Turkish tax data,
    
*   local Pillar Two requirements,
    
*   domestic minimum top-up tax,
    
*   local safe harbour implications,
    
*   Turkish returns and notifications, and
    
*   reconciliation with the global workstream.
    

In other words:

> **Your global adviser can manage Pillar Two globally. We can manage the Turkish compliance layer.**

* * *

## Turkey Pillar Two Advisory and Compliance Support

OZM Consultancy assists multinational groups, foreign-owned Turkish companies and overseas tax teams with the **Turkish component of Pillar Two compliance**.

Depending on the engagement, our work may include:

*   Turkey Pillar Two scope assessment,
    
*   identification of Turkish constituent entities,
    
*   review of the group ownership structure,
    
*   Turkish QDMTT assessment,
    
*   IIR and UTPR analysis,
    
*   safe harbour review,
    
*   identification of Turkish data requirements,
    
*   coordination with the group's global Pillar Two adviser,
    
*   review of Turkish statutory tax information against GloBE data, and
    
*   Turkish Pillar Two filing and compliance support.
    

Our role can therefore be limited to the Turkish workstream without replacing the group's existing global Pillar Two adviser.

* * *

## Need a Turkey Pillar Two Scope Review?

If your multinational group has **EUR 750 million or more in consolidated revenue** and one or more companies in Turkey, we can perform an initial review of the Turkish Pillar Two position.

For an efficient initial assessment, please provide:

*   Ultimate Parent Entity jurisdiction,
    
*   latest consolidated group revenue,
    
*   list of Turkish entities,
    
*   group organisation chart,
    
*   relevant accounting period, and
    
*   details of your existing Pillar Two/GloBE reporting process.
    

**Contact OZM Consultancy to request a Turkey Pillar Two scope and compliance assessment.**

**Email:** [info@ozmconsultancy.com](mailto:info@ozmconsultancy.com)

We can coordinate directly with your **Group Tax Director, CFO, finance team or existing international Pillar Two adviser** to manage the Turkish compliance workstream.

* * *

## Frequently Asked Questions

### Does Pillar Two apply to every Turkish company?

No. The rules are primarily relevant to entities belonging to multinational groups meeting the applicable EUR 750 million consolidated revenue threshold and other scope conditions.

### Does the Turkish subsidiary itself need EUR 750 million of revenue?

No. The threshold is assessed at multinational group level under the applicable rules. A comparatively small Turkish subsidiary may therefore still be part of an in-scope group.

### Is Turkey's corporate income tax rate enough to determine Pillar Two liability?

No. Pillar Two uses a separate GloBE effective tax rate methodology.

### Does Turkey have a domestic minimum top-up tax?

Yes. Turkey's Pillar Two framework includes a domestic minimum top-up tax mechanism.

### Is there a Pillar Two tax return in Turkey?

Yes. Turkey has implemented Global Minimum Top-Up Corporate Tax filing requirements.

### Was a Turkish Pillar Two return required for the 2024 accounting period?

Yes. For the 2024 accounting period, the deadline for the Global Minimum Top-Up Corporate Tax Return and payment was extended to **31 July 2026**.

### Can Pillar Two safe harbours apply in Turkey?

Potentially. The applicable safe harbour should be assessed based on the group's facts, the relevant jurisdiction and current Turkish rules, including the framework reflected in Presidential Decision No. 11511.

### Can OZM Consultancy work with our existing global Pillar Two adviser?

Yes. The Turkish compliance workstream can be handled locally while the group's existing adviser continues to manage the global GloBE calculation and overall Pillar Two project.

* * *

*Last updated: August 2026.*

*This publication is provided for general information only and does not constitute tax advice. Pillar Two treatment depends on the group's consolidated financial statements, ownership structure, accounting period, relevant jurisdictions, GloBE calculations, available safe harbours and other facts and circumstances.*