Revenue Administration has finalised Pillar 2 GMT rules, detailing top-up tax, IIR, and UTPR for large MNEs.
The Turkish Revenue Administration finalised the implementation rules for the Pillar 2 Global Minimum Tax (GMT) and submitted the General Communiqué to the Presidency for signature and publication.
This announcement was made on 12 December 2025.
The rules, approved under Law No. 7524, introduce a domestic minimum top-up tax, an income inclusion rule (IIR), and an undertaxed profits rule (UTPR) for multinational enterprise (MNE) groups with annual revenues exceeding the Turkish lira equivalent of EUR 750 million in at least two of the four preceding accounting periods.
The reform also establishes a 10% minimum corporate tax, incorporates safe harbour provisions aligned with OECD guidance, and adjusts the tax treatment of investment funds and certain project earnings.
The domestic minimum top-up tax and the IIR apply to accounting periods from 1 January 2024, while the UTPR takes effect from 1 January 2025.
Earlier, the Turkish Revenue Administration released a draft General Communiqué for public consultation, setting out the framework for implementing the Pillar 2 Global Minimum Tax (GMT) on 3 October 2025.
