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Turkey Expands Scope of E-Documents

Enis Gencer
November 17, 2021

The Turkish Revenue Administration (TRA) published a Draft Communique that includes significant changes to the Tax Procedure Law General Communique No. 509, which initially aimed to unify all e-document regulations when it was published in October 2019.

With the Draft Communique, the TRA will lower the current gross sales revenue threshold for mandatory e-fatura and e-delivery note applications. The total amount for invoices that must be issued as e-arsiv invoices will also be lowered. This means more taxpayers will be required to use these applications.

In addition, the TRA will include a new sector-based mandatory transition requirement to the scope of the e-fatura and e-delivery note application. Other changes are also proposed for e-exchange receipt and e-note of expense.

Currently open for public consultation, opinions and suggestions will be accepted by the TRA until 1 December 2021 through eyeniaras@gelirler.gov.tr

The scope of e-fatura to be expanded

  • The gross sales revenue threshold will be decreased gradually. The current threshold limit is TRY 5 million. The use of the e-fatura application will be mandatory for taxpayers with gross sales revenue of TRY 4 million and above for the 2021 financial period, and TRY 3 million and above for 2022 and all subsequent financial periods.
  • The use of e-fatura will be mandatory for taxpayers in the e-commerce sector when exceeding a certain threshold. The Draft Communique introduces a gross sales revenue threshold of TRY 1 million and above for 2020 and 2021 financial periods; and TRY 500.000 for 2022 and all subsequent financial periods.
  • Taxpayers who run a business in the real estate and/or motor vehicle sector by carrying out construction, manufacture, purchase, sale, and rental transactions, as well as intermediaries in these transactions will use the e-fatura application if their gross sales revenue exceeds TRY 1 million and above for 2020 and 2021 financial periods; and TRY 500.000 for all subsequent financial periods.
  • Taxpayers who provide accommodation services by obtaining investment and/or operation certificates from the Ministry of Culture and Tourism and Municipalities will use the e-fatura application.

Taxpayers meeting these thresholds and criteria must start using the e-fatura application from the beginning of the year’s seventh month following the relevant accounting period.

Scope of e-arsiv invoice to be expanded

According to the General Communique, taxpayers not in scope of e-arşiv invoice are obliged to issue e-arşiv invoices in case the total amount of the invoices to be issued exceeds TRY 30.000 including taxes (in terms of invoices issued to non- registered taxpayers, the total amount including taxes exceeds TRY 5.000) from 1 January 2020.

With the Draft Communique, the TRA will lower the total amount of the invoice threshold to TRY 10.000, and thus more taxpayers will be required to use the e-arsiv application.

Scope of e-delivery note to be expanded

Another change introduced by the Draft Communique is to expand the scope of e-delivery notes. According to the Draft Communique, the gross sales turnover threshold for mandatory e-delivery notes will be revised as TRY 10 million effective from the 2021 accounting period. In addition, taxpayers who manufacture, import, or export iron and steel (GTIP 72) and iron or steel goods (GTIP 73) will be required to use the e-delivery note application. The condition to be registered for the e-fatura application will not apply to those taxpayers.

What’s next?

Turkey is rapidly expanding the scope of its e-documents, and from the Draft Communique, it’s clear that digital tax transformation is ongoing. After the public consultation deadline, the TRA might review the feedback received from stakeholders and finalize the Draft Communique provisions.

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Enis Gencer

Enis Gencer is Regulatory Counsel at Sovos and is based in Istanbul, Turkey. With experience in compliance and legal consultancy he currently undertakes the legal monitoring and analysis of the regulations regarding electronic documents. Enis graduated from Istanbul University Faculty of Law.
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