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Turkey Expands Scope of E-Documents

Enis Gencer
February 2, 2022

Towards the end of 2021, the tax authority in Turkey published a draft communique that expands the scope of e-documents in Turkey. After minor revisions, the draft communique was enacted and published in the Official Gazette on 22 January 2022.

Let’s take a closer look at the changes in the scope of Turkish e-documents.

Scope of e-fatura expanded

  • The gross sales revenue threshold will decreased reduce. The threshold limit has been lowered from TRY 5 million to TRY 4 million and above for the 2021 financial period. A lower threshold of TRY 3 million and above will apply for 2022 and subsequent fiscal periods.
  • The use of the e-fatura is now mandatory for taxpayers in the e-commerce sector when exceeding a certain threshold. The communique introduced 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 fiscal periods.
  • Taxpayers who run a business in the real estate and/or motor vehicle sector by carrying out construction, manufacturing, purchase, sale, and rental transactions, as well as taxpayers who act as intermediaries in these transactions must 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 2022 and all subsequent fiscal periods.
  • Taxpayers who provide accommodation services by obtaining investment and/or operation certificates from the Ministry of Culture and Tourism and Municipalities must use the e-fatura application.

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

In terms of accommodation service providers, if they provide services as of the publication date of this communique, they must start using the e-fatura application from 1 July 2022.

For any business activities that start after the publication date of the communique e-fatura must be used from the beginning of the fourth month following the month in which their business activities began.

E-arsiv invoice scope expanded

Taxpayers not in scope of e-arşiv invoices have been obliged to issue e-arşiv invoices if 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 amended communique, the Turkish Revenue Administration (TRA) lowered the total amount of the invoice threshold to TRY 5.000, and thus more taxpayers will be required to use the e-arsiv application. The new e-arsiv invoice threshold applies from 1 March 2022.

E-delivery note scope expanded

Another change introduced by the communique was the expansion of the scope of e-delivery notes. The gross sales turnover threshold for mandatory e-delivery notes has been revised to 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) are required to use the e-delivery note application. E-fatura application registration is not applicable to those taxpayers.

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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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