Sworn CPA (YMM) Becomes Mandatory for Turkish Companies
Who Is Required to Work with a Sworn-in CPA as of 2025 and 2026 ?
Sworn CPA (YMM) Becomes Mandatory for Turkish Companies
Who Is Required to Work with a Sworn-in CPA as of 2025 and 2026?
Introduction: A Structural Shift in Turkish Tax Compliance
With the publication of General Communiqué No. 49 in the Official Gazette dated 30 December 2025, Turkey has entered a new phase of tax compliance.
From the 2025 tax year onward, benefiting from income tax or corporate tax exemptions, incentives, or reduced tax applications is no longer merely a declaration matter. In many cases, it is now explicitly conditional upon certification by a Sworn-in Certified Public Accountant (Yeminli Mali Müşavir – YMM).
This regulation significantly expands the scope of mandatory sworn CPA involvement, especially for companies applying tax incentives, investment deductions, export exemptions, and the newly introduced local and global minimum top-up corporate tax.
This article explains, in practical terms, who must work with a Sworn CPA in Turkey, starting from 2025.
Legal Basis of the Obligation
The obligation is grounded on:
Article 227 (repeated) of the Turkish Tax Procedure Law
Articles 12 and 32/A of the Corporate Tax Law
Income Tax Law No. 193
Corporate Tax Law No. 5520
General Communiqué No. 49 (Official Gazette No. 33123)
The Ministry of Treasury and Finance is explicitly authorized to condition the use of tax exemptions and incentives on YMM certification reports.
1. Income Taxpayers: Who Must Obtain a Sworn CPA Report?
Mandatory YMM Certification Applies If:
Income tax taxpayers (sole proprietors, freelancers, partners, digital professionals, etc.) must work with a Sworn CPA if they declare:
A. Single Exemption or Deduction Exceeding TRY 500,000
If any individual exemption or deduction item (other than “other deductions/other exemptions”) exceeds TRY 500,000, a YMM certification report becomes mandatory.
B. Multiple Exemptions Totaling More Than TRY 1,000,000
Even if each exemption is below TRY 500,000, but their aggregate amount exceeds TRY 1,000,000, all exemptions must be certified by a YMM.
C. “Other Deductions / Other Exemptions” Line Exceeds TRY 1,000,000
If the total amount reported under:
“Other Deductions”, or
“Other Exemptions”,
or both combined exceeds TRY 1,000,000, YMM certification is compulsory.
D. Reduced Income Tax under Article 32/A
For investment-based reduced income tax applications, no monetary threshold applies.
Any use of this incentive automatically triggers mandatory YMM involvement.
2. Corporate Taxpayers: Which Companies Are Covered?
The regulation has even broader consequences for corporate taxpayers (Ltd., A.Ş., branches, PE structures).
A. Corporate Tax Exemptions and Deductions Over Thresholds
A Sworn CPA report is mandatory if the company declares:
Any single exemption or deduction exceeding TRY 500,000, or
Multiple exemptions whose total exceeds TRY 1,000,000.
B. Reduced Corporate Tax Rate Applications
Mandatory YMM certification applies if:
The tax advantage exceeds TRY 200,000, or
The incentive is granted under Article 32/A (investment incentive regime), regardless of amount.
3. Local & Global Minimum Top-Up Corporate Tax (OECD Pillar Two)
One of the most critical expansions introduced by the Communiqué concerns the local and global minimum corporate tax regime.
Key Point:
For companies subject to:
Domestic minimum top-up tax, or
Global minimum tax (Pillar Two)
👉 There is NO monetary threshold.
👉 YMM certification is mandatory in all cases.
This directly impacts:
Multinational groups
Turkish subsidiaries of foreign groups
Large technology, SaaS, gaming, and holding structures
4. From Which Period Does the Obligation Apply?
The rules apply to:
Calendar-year taxpayers: From 2025 tax year onward
Special accounting period taxpayers: From the first accounting period starting in 2025
Thresholds will be automatically increased each year by 50% of the revaluation rate, unless the Ministry determines otherwise.
5. What Happens If You Do Not Submit a YMM Report?
Failure to submit the required Sworn CPA certification results in:
Loss of the tax exemption or incentive
Special irregularity penalties under the Tax Procedure Law
Formal grace period may be granted, but rights are forfeited if not cured
In short:
No YMM report = no tax benefit.
6. Can Companies Voluntarily Work with a Sworn CPA?
Yes.
Even if thresholds are not exceeded, taxpayers may voluntarily request YMM certification to:
Strengthen audit defensibility
Reduce tax risk
Increase credibility before tax authorities
Protect management and shareholders
7. Important Exception: Public Enterprises (KİT)
Public Economic Enterprises governed by Decree Law No. 233 are explicitly excluded from the mandatory certification requirement.
Strategic Implications for Companies
This regulation marks a clear policy shift:
Tax incentives are no longer “self-assessed”
Substance, documentation, and audit trail are now central
Sworn CPAs carry joint and several liability with the taxpayer
For companies using:
Investment incentives
Software & R&D exemptions
Export-based tax benefits
International tax structuring
Pillar Two compliance
👉 Early coordination between CPA and Sworn CPA is no longer optional—it is essential.
Reach us
If your company benefits from tax exemptions, reduced tax rates, investment incentives, or minimum tax regimes in Turkey, you should assess immediately whether you fall within the scope of mandatory Sworn CPA certification.
Reach us for Sworn CPA Services
info@ozmconsultancy.com
