Turkey's E-Transformation Journey

Turkey has one of the most established Continuous Transaction Controls (CTC) systems in place outside of Latin America

Turkey’s e-transformation started with an e-invoicing mandate in 2012 and evolved with the introduction of e-arşiv invoice which provided the Turkish tax authority with real-time control on the invoices exchanged. The tax authority has also introduced e-delivery note to monitor the transport of goods in 2017.  Taxpayers above a certain threshold or/and in certain sectors are now obliged to use e-transformation applications.

Through time the number of taxpayers needing to comply with the mandates has grown as the thresholds for eligibility have reduced and new taxpayer groups added in the scope of the mandate. 

As a result, businesses need to adopt a system capable of managing various e-applications and reducing the complexity of these applications.

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Mandate quick facts

  • Turkey has four major mandated e-transformation applications, and mandates including archiving of the e-document.

  • Turkey’s e-invoicing mandate has two major applications: e-invoice (B2B) and e-arşiv invoice (B2B & B2C).

  • Introducing the clearance model e-invoice application in 2013, Turkey is one of the pioneers of clearance e-invoicing besides Latam countries.

  • E-arşiv invoice introduced in 2016, is a CTC-reporting model; it can be exchanged in paper form but it must be issued electronically and all e-arşiv invoices must be reported to the Turkish Revenue Administration(TRA) daily.

  • E-ledger mandate obliges taxpayers to electronically create, sign, and archive their cash blotter and general ledgers and report those ledgers’ summaries (berats) to TRA monthly or quarterly.
  • E-delivery notes must be issued and approved by the TRA or special integrator to start the transportation of the goods.

  • Uses a localized format of UBL 2.1 for e-invoice, e-arşiv invoice, e-delivery note, and XBRL-GL for e-ledger.

Upcoming Mandate Rollouts

  • 1 January 2021: Those with a 2018 or 2019 revenue exceeding TRY 5m must start using e-ledger application due to e-invoice mandate

  • Taxpayers with revenue exceeding TRY 5m must start using e-invoicing applications by the seventh month of the following year.

  • Taxpayers who start using e-invoicing applications after the seventh month have to start using e-ledger application by the beginning of the following year.

  • Certain taxpayer groups, including online traders and Middlemen or merchants trading fruits or vegetables, must start using e-invoicing applications within three months and e-delivery note application within four months after establishing their business.

Penalties

  • Not complying with the e-invoicing mandates will result in a fine that is 10% of the actual amount or of the missing amount of an e-invoice (e-invoice, e-arşiv invoice and export invoices). The fine can’t be lower than TRY 350 (approx. EUR 50) per invoice and the maximum fines might reach TRY 180,000 (approx. EUR 25,700) annually per document type.

  • Failure to comply with e-delivery note mandate will result in a TRY 350 (approx. EUR 50) fine per document. The maximum fines might reach TRY 180,000 (approx. EUR 25,700) annually.

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