Tax Audits in Turkey: Company Rights and Defence

09 Ekim 2026 · Av. Sinan Cem GÖDE

This is the English version of an article originally published in Turkish: Vergi İncelemesi Sürecinde Şirketlerin Hakları ve Savunma Yol Haritası.

A letter arriving at a company’s accounts department is often the first step in a long process. A tax audit (vergi incelemesi) is a technical review in which the company’s tax returns are checked against its books and documents. Handled properly, it usually ends with a limited adjustment. Neglected, it can end in substantial assessments and penalties.

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This article explains the rights a company has at each stage of a tax audit in Turkey and the routes that remain open once an assessment is proposed. It applies equally to Turkish subsidiaries and branches of foreign groups.

In short: a tax audit is an administrative review of whether the tax due has been correctly calculated, carried out on the basis of books, records and documents. As a rule it takes place at the tax office, and it should be completed within one year for a full audit and six months for a limited audit. The company’s right of defence begins when the audit minutes are drawn up and continues through to litigation.

Why a tax audit matters for a company

The purpose of an audit is to establish the true amount of tax payable. The tax inspector compares the company’s returns with its books and documents, and where a discrepancy is found, an assessment is proposed for the difference.

The issue is not only the tax itself. A tax loss penalty (vergi ziyaı cezası) is added to the difference in the tax base, and in some cases a penalty of up to three times the tax, together with late payment interest, may apply. Serious allegations, such as the use of false invoices, can also turn into the criminal offence of tax evasion (in Turkish). Taking the right position from the first day is therefore important.

Legal framework and time limits

Audits are governed by the Tax Procedure Law (No. 213, “VUK”). Following the amendment made by Law No. 7338, the rule since 1 July 2022 has been that audits are carried out at the tax office.

Where the audit takes place

Under VUK Article 139, tax audits are, in principle, carried out at the tax office. The taxpayer is asked in writing to bring the necessary books and documents to the office. If the taxpayer requests it and the business premises are suitable, the audit may also be conducted at the place of business.

This places the audit on a documented and traceable footing. The company must produce the requested books and documents within the time allowed. Documents that are not produced may lead to adverse findings.

How long an audit lasts

VUK Article 140(6) provides that audits should, as a rule, be completed within the following periods from the date the audit begins:

• Full audit: one year, with a possible extension of up to six months.
• Limited audit: six months, with a possible extension of up to six months.
• VAT refund audit: three months, with a possible extension of up to two months.

Exceeding these periods does not by itself invalidate an assessment. However, whether the audit was conducted in accordance with procedure can strengthen the company’s hand at later stages.

The company’s rights during the audit

An audit is not a one-sided interrogation. The taxpayer has rights under the law, and knowing them is the basis of any defence. The main rights are:

• to be informed in writing that the audit has begun and of its subject matter (VUK Article 140 expressly requires this at the start of the audit);
• to see the identification of the tax inspector;
• to hand over and receive back books and documents against signed minutes;
• to have objections and explanations recorded in the audit minutes (tutanak); and
• to obtain a copy of the minutes.

The minutes are the key document of the process. Once signed, they are relied on at every later stage, so the right to have objections and explanations written into them should be used with care.

The audit step by step

1. Start of the audit: the subject and scope are notified in writing.
2. Production of books and documents: the requested records are delivered on time.
3. Examination and minutes: findings are recorded in the minutes, and objections are entered there.
4. Report review: the audit report is reviewed for legal compliance by the report evaluation committee (rapor değerlendirme komisyonu).
5. Assessment and penalty: the tax and penalty notice (vergi/ceza ihbarnamesi) is served.

A hypothetical example: a manufacturing company’s 2024 accounting period is placed under a limited audit. The inspector treats a purchase invoice of TRY 400,000 as unsupported and proposes an increase in the tax base, together with a tax loss penalty. If the company attaches the payment and delivery documents relating to that invoice to the minutes, the proposed adjustment may be substantially reduced. Every file, of course, depends on its own documents.

Responding to an assessment: explanation, settlement or litigation

A company facing a proposed assessment has more than one route. The right one depends on the nature of the case and the strength of the documents.

• Invitation to explain (izaha davet): available before assessment for certain preliminary findings. If the explanation is accepted, no assessment is made; if not, a reduced penalty may be available.
• Settlement (uzlaşma): available before or after assessment. It can reduce the tax and penalty and ends the dispute at the administrative stage.
• Litigation: an action before the tax court within 30 days of service of the notice. The assessment is reviewed by the court, and collection can be suspended.

These routes are alternatives, and some close off others. For example, once a settlement is reached, the same assessment can no longer be challenged in court. The choice is difficult to reverse. See also the separate articles on settlement procedures (in Turkish) and court actions against tax notices (in Turkish).

Three common mistakes

• Signing the minutes without reading them. The minutes form the basis of later stages. Objections and explanations that are not recorded are harder to raise afterwards.
• Producing documents late or incompletely. A document not produced during the audit may be disregarded, and submitting the same document at the litigation stage does not always have the same effect.
• Missing the 30-day deadline to sue. This period runs from service of the notice and is a strict time bar. Once it expires, the assessment becomes final and the ex officio assessed tax (in Turkish) moves to collection.

The approach of the tax courts

Settled case law is clear on two points. The first is the importance of procedural safeguards: failure to notify the subject of the audit is treated as a defect that restricts the right of defence.

The second concerns the burden of proof. According to the consistent approach of the Council of State (Danıştay), the party asserting a situation that does not fit economic and commercial norms, or that is not supported by documents, must prove it. Keeping complete payment, delivery and contract records is therefore decisive at the litigation stage.

Practical points

A tax audit can have serious consequences, but it is a manageable process. Exercising rights on time, signing the minutes with care and choosing the right response to an assessment often decide the outcome. The time limits are strict, so each stage calls for prompt action. For foreign-owned companies, it helps to agree in advance who will deal with the tax inspector and how documents held abroad will be produced within the time allowed.

More information for foreign clients: English-speaking lawyer in Ankara.

This article provides general information on Turkish law and is not legal advice. Outcomes depend on the facts of each case.