Turkey Publishes e-Delivery Application Manual

Selin Adler Ring
March 11, 2020

The Turkish Revenue Administration (TRA) has now published the long-awaited e-Delivery Note Application Manual. The manual clarifies how the electronic delivery process will work and answers frequently asked questions. It addresses the application as well as its scope and structure, outlines important scenarios and provides clarity for companies who are unclear about the adoption of e-delivery notes.

What is the e-delivery note application?

The e-delivery note is the electronic version of the “delivery note,” which is currently printed on paper.  It allows the TRA to regularly monitor the movements of delivered merchandise in the electronic environment.

Electronic delivery has the same legal qualifications as the delivery note but is issued, forwarded, retained, and submitted digitally.

Who does the e-delivery note mandate affect?

According to the circular published by the TRA at the end of February, taxpayers in scope of the e-delivery note application are;

  • E-invoice taxpayers with a gross sales turnover of 25 million TL and above
  • Companies with an Energy Market Regulatory Authority (EPDK) license (including dealers) -PCT I
  • Motor vehicles (production, import, dealers) – PCT III
  • Mining license owners and producers of mine based on their contracts with these people
  • Sugar manufacturers
  • Iron and steel manufacturers / HS Code72 / HS Code73
  • Users registered in the fertilizer tracking system
  • Taxpayers engaged in fruit and vegetable trade as brokers or merchants
  • Taxpayers who are found to be risky or at low levels of tax compliance as a result of the Administrative analysis

Taxpayers engaged in fruit and vegetable trade as brokers or merchants completed their transitions of January 1, 2020. Other taxpayers covered by the mandate must be ready by July 1, 2020.

Taxpayers deemed to be risky or at low levels of tax compliance by the TRA must complete their transition to the e-delivery note application within three months after being notified.

Other topics included in the e-delivery note application manual

Besides explaining the basic concepts, the manual details the previously announced scenarios providing answers to many areas that were confusing for taxpayers.

The main scenarios are:

  • Delivery notes to be issued for the buyers not registered in the e-delivery note application
  • Export and logistic scenarios
  • Successive delivery
  • Issuing a printed delivery note
  • Various customers

Other topics covered include:

  • Market registry system
  • Fuel oil sector
  • Transportation by pipelines
  • Sample and contract manufacturing processes

Full details are available in Turkish from the TRA e-Document website.

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Author

Selin Adler Ring

Selin is Regulatory Counsel at Sovos. Based in Stockholm and originally from Turkey, Selin’s background is in corporate and commercial law, and currently specializes in global e-invoicing compliance. Selin earned a Law degree in her home country and has a master’s degree in Law and Economics. She speaks Russian, Arabic, English and Turkish.
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