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Turkish Revenue Authority Publishes New Rules for e-Documents

Selin Adler Ring
February 11, 2021

Back in July 2020, the Turkish Revenue Authority (TRA) published a Draft Communique including several amendments to existing e-document regulations. Very recently, on 9 February 2021, the Draft Communique amendments were implemented into a new Communique, amending General Communique (‘Amending Communique’) with some changes, exemptions and additional provisions. Let´s take a closer look at the final outcome of the changes.

E-invoice and e-arşiv invoice mandate for healthcare service providers

The issuance of e-invoice and e-arsiv invoice will be mandatory for healthcare service providers (pharmacies, hospitals, medical product suppliers, opticians, laboratories etc.) The deadline to comply with this requirement is 1 July 2021.

E-arşiv invoices can be issued using a special integrator

It was previously mandated that invoices with a value above 5.000/30.000 TL had to be issued as e-arsiv invoices using the TRA portal. After the recent changes it is now possible for taxpayers to use a special integrator to issue e-arsiv invoices.

Mandatory issuance of e-Tab

In line with the Draft Communique, the e-Tab has been introduced as a new electronic document type. This is a mandatory document for businesses that provide services at the table (such as restaurants, bars and cafes) which was previously issued in paper form. E-tab is now mandatory for these types of businesses depending on their turnover. The threshold limit and the timelines will be announced by the TRA at a later date.

E-foreign exchange receipt (e-Fer) scope expanded

Even though it was not envisaged in the Draft Communique, another development regarding the scope of e-Fer has now been introduced in the Amending Communique. While gaps still remain surrounding this type of e-doc due to the fact that the technical specifications have not yet been published, it is clear that banks are included in the current scope of e-Fer and that the document is not yet mandatory.

Ex-officio registration of taxpayers by the TRA

If taxpayers are not registered within the TRA system for e-documents that are mandated for them, the TRA will create user accounts for those taxpayers for the mandated document applications.

Cancellation, rejection and denunciation notices can be performed electronically

It was not always possible for taxpayers to reject/cancel or denunciate e-documents electronically. Instead, this was generally performed through a notarised document communicated to the supplier outside of the TRA system. In order to have a point-to-point electronic process, the TRA decided to change this application and it will now be possible to perform these activities for e-documents electronically once the technical documentation is made available by the TRA.

Turkey has an ambitious digital transformation plan and the authorities do not hesitate to challenge taxpayers by enacting new rules each quarter. To remain compliant in such a demanding jurisdiction, taxpayers should allocate enough time and resources to stay up-to-date with the latest changes.

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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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