# Sworn CPA (YMM) Becomes Mandatory for Turkish Companies # 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: 1. **Loss of the tax exemption or incentive** 2. **Special irregularity penalties** under the Tax Procedure Law 3. 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 ![](https://cdn.hashnode.com/res/hashnode/image/upload/v1767062722354/4af0fb90-656b-46d3-8876-5eef169a73be.png align="center")