General Communiqué No. 25 sets out guidance on domestic minimum corporate income tax, REIT profit distribution requirements, exemption treatment and the reintroduced fourth advance tax period, effective from 24 May 2026.
Turkey’s Revenue Administration has issued General Communiqué No. 25, providing detailed implementation guidance on recent amendments to the Corporate Tax Law introduced by Law No. 7524 and Law No. 7566.
The Communiqué, published in the Official Gazette on 24 May 2026, clarifies the application of the domestic minimum corporate income tax, exemption rules for investment funds and partnerships, and procedures for the reintroduced fourth advance tax period.
Under the new guidance, real estate investment trusts (REITs) must distribute at least 50% of qualifying earnings from immovable property activities to retain their corporate income tax exemption. The Communiqué confirms that advance dividends (avans kâr payı) derived from income earned from 1 January 2025 will count towards meeting this distribution requirement. It also sets out rules for allocating common expenses and depreciation between qualifying and non-qualifying activities.
The Communiqué further distinguishes between activity-based and transaction-based exemptions. For activity-based exemptions, including those applicable in technology development zones, free zones and investment funds, profits and losses from all covered activities must be assessed together. For transaction-based exemptions, such as participation exemptions and certain real estate sales exemptions, gains and losses must be evaluated separately, with losses treated as non-deductible expenses where applicable.
In relation to the domestic minimum corporate income tax, the guidance confirms that only investment amounts recorded in investment incentive certificates before 2 August 2024 may be considered when calculating the investment contribution amount deductible from minimum tax. Any increases resulting from certificate revisions made after that date are excluded. The Communiqué also establishes the administrative framework for the declaration and payment of advance tax under the reintroduced fourth advance tax period.
General Communiqué No. 25 entered into force on 24 May 2026.
