This is the English version of an article originally published in Turkish: Vergi Dairesi Hesabıma Haciz Koydu: Bloke Nasıl Kaldırılır?.
You open your banking app one morning and find the account frozen, with the name of a Turkish tax office in the description. Most people assume the seizure came out of nowhere that day. In fact, an electronic bank account seizure (e-haciz) is not the start of the process but its end.
This article explains how a tax office seizure of a bank account can be lifted in Turkey, starting with the documents on which the seizure is based: when each time limit starts, what routes exist to release the freeze and which objections actually work. The framework is Law No. 6183 on the Collection Procedure of Public Receivables.
Where the seizure comes from: the payment order
A tax office does not seize an account directly for a debt that was not paid on time. The law first requires a payment order (ödeme emri). Under Article 55 of Law No. 6183, the payment order requires the debtor to pay within 15 days or, within the same period, to make a declaration of assets (mal bildirimi). Law No. 7061 extended this period from seven to 15 days with effect from 1 January 2018.
If the debt is not paid within that period, the collecting office may proceed to seizure. Seizure of bank accounts is now largely carried out electronically: Article 79 allows seizure notices to be sent to banks by electronic means, which is what is known in practice as e-haciz.
Article 62 sets out the basis of the seizure: the collecting office seizes, from the debtor’s movable and immovable property, receivables and rights, whether held by the debtor or by third parties and whether shown in the declaration of assets or identified by the office, an amount sufficient to cover the public receivable. The words “an amount sufficient” are the starting point for the argument on excessive seizure discussed below.
Which debts can lead to seizure?
The tax office collects more than taxes. Alongside income tax, VAT and corporate tax, motor vehicle tax, traffic fines and tax penalties are collected under the same law, and the payment order and seizure process works the same way for all of them.
Social security premium debts are different. The Social Security Institution (SGK) pursues these itself, applying the provisions of Law No. 6183. The first step is therefore to establish which authority the freeze comes from. The bank can tell you which institution sent the seizure notice; applying to the tax office only helps if the seizure came from it.
“I never saw the notice.” Did time still run?
In most e-haciz cases the real question is when the payment order is deemed to have been served. Companies and many taxpayers now receive notices at their electronic notification address (e-Tebligat). Under Article 107/A of the Tax Procedure Law (No. 213, “VUK”), electronic notification is deemed made at the end of the fifth day following the date it reaches the recipient’s address. Whether the message was opened does not change this.
On the day you discover the freeze, the first task is to find out the date on which the payment order was served. The debt statement and notifications can be accessed through the online tax office (İnteraktif Vergi Dairesi). The date of service decides whether the right to sue is still open. Foreign companies and individuals who do not check their e-Tebligat inbox regularly are particularly exposed here. For more on electronic notification, see the article on service of tax notices (in Turkish).
The time limits at a glance
- Payment of the debt or declaration of assets: 15 days from service of the payment order (Law No. 6183, Article 55).
- Court action against the payment order: 15 days from service of the payment order (Law No. 6183, Article 58).
- Court action against a tax or penalty notice: 30 days from service of the notice (Administrative Procedure Law No. 2577, Article 7).
- Deemed service of e-Tebligat: end of the fifth day following arrival at the address (VUK Article 107/A).
- Limitation period for collection: 5 years from the start of the year following the year in which the debt fell due (Law No. 6183, Article 102).
A worked example
The following example is hypothetical and only shows how the time limits work. A limited company owes TRY 180,000 in overdue VAT. The tax office sends the payment order to the company’s e-Tebligat address on 3 March. Even if the message is never opened, service is deemed made at the end of the fifth day, on 8 March. The 15-day period for payment and for suing starts on 9 March and ends on 23 March.
On 28 March the company discovers freezes on three bank accounts totalling TRY 1,200,000. The time to sue against the payment order has passed, but the options are not exhausted. A freeze of roughly six times the debt is open to challenge under the rule that seizure is limited to an amount sufficient to cover the debt. The company can also apply for deferral. If it turns out that the tax notice behind the debt was never served, or was served improperly, the dispute moves onto entirely different ground.
The right order for this company is: first, examine the service records for the payment order and the tax notice; second, check whether the seizure is proportionate to the debt and apply for release of the excess; third, decide whether payment, deferral or litigation is the right response to the debt itself. Reversing this order, for example paying in full without looking at any documents, can weaken objections that could otherwise be raised later.
Ways to lift the freeze
Paying the debt
This is the quickest route. Once payment is made, the tax office notifies the bank that the seizure has been lifted, which usually shows in the system the same day or the next working day. If the freeze remains after payment, a written application to the tax office is needed.
Deferral and instalments
Article 48 of Law No. 6183 allows deferral (tecil) where paying the debt on time, or enforcing the seizure, would put the debtor in serious difficulty. The debtor must apply in writing and provide security. Deferral cannot exceed 36 months and deferral interest applies. No security is required up to a certain amount; under a Presidential Decree published in June 2026, this threshold was raised to TRY 10 million (source in Turkish).
Once deferral is granted, enforcement stops for the deferral period. Whether existing seizures are lifted is assessed with the tax office according to the security provided. The rule often seen online, “pay twenty per cent up front and the freeze is lifted”, does not exist in the law.
Serious difficulty cannot be shown by a bare statement. For businesses, financial statements, cash flow and the balance of receivables and payables form the basis of the assessment, and filing the application with these documents speeds up the review. What stops enforcement is the decision granting deferral, not the application itself, so a new seizure remains possible until the decision is made.
Restructuring laws
Restructuring laws enacted from time to time provide reductions in interest and penalties. Their provisions on seizures differ: some allow seizures to be lifted in proportion to payments made, while others only suspend the sale of seized assets. The seizure provision of the relevant law should be read before applying.
Court action and stay of execution
An action against a payment order may rest on the three grounds listed in Article 58: no such debt exists, the debt has been partly paid, or the debt is time-barred. Bringing the action does not by itself stop collection. For the freeze to be lifted while the case is pending, a stay of execution (yürütmenin durdurulması) must be specifically requested in the statement of claim. Details are covered in the article on challenging a payment order (in Turkish).
When can limitation be raised?
Under Article 102 of Law No. 6183, a public receivable becomes time-barred if it is not collected within five years from the start of the calendar year following the year in which it fell due. The point most often overlooked is that this period can be interrupted. Article 103 lists the acts that interrupt it, the most common in practice being:
- payment of the debt;
- service of a payment order;
- enforcement of a seizure;
- a declaration of assets; and
- provision of security.
After an interruption, the period starts again from the beginning of the year following the year of the interrupting event. Saying “the debt is five years old” is therefore not enough: every dated step in the file must be identified.
Excessive seizure, salaries and pensions
By law, seizure is limited to an amount sufficient to cover the debt. Freezing all accounts and receivables for a small debt may exceed that limit. In that case, the debtor can ask the tax office to release the excess by a petition showing the amount of the debt and the assets seized. If the request is refused, the decision is subject to judicial review.
Salaries and wages can only be seized within the limits set by Article 71 of Law No. 6183. Pensions enjoy separate protection: Article 93 of the Social Insurance and General Health Insurance Law (No. 5510) prohibits their seizure except for maintenance debts and debts to the Social Security Institution. Where the frozen account is the one into which a salary or pension is paid, the application should be supported by a document showing the nature of the incoming payments.
Preparing the application
The application to lift the seizure should be short but complete. The first paragraph should make clear what is requested: release following payment, deferral, restructuring or release of an excessive seizure. The tax identification number, the type and period of the debt and the details of the frozen accounts should all be included.
Supporting documents speed up the process: a payment receipt, the deferral decision, or a statement showing that the money paid into the account is a salary or pension. Applications can also be made through the online tax office. If a petition is handed in at the office, obtain a date and reference number, which makes it easier to prove the application if a dispute arises later.
Common mistakes
- Thinking the period is seven days. The seven-day period found in older sources has not applied since 2018. The opposite mistake is more dangerous: assuming the time to sue against a payment order is 30 days, as for tax notices. It is 15.
- Suing but forgetting the declaration of assets. Bringing an action does not remove the obligation to declare assets that the payment order imposes. A debtor with no assets can still make a declaration: “I have no assets” is a valid declaration.
- Not asking for a stay of execution. If the statement of claim does not include this request, the seizure continues while the case is pending. Winning the case later does not undo the damage of accounts frozen for months: payments are disrupted and supplier relationships suffer.
Principles from the case law
Under the settled case law of the Council of State (Danıştay), a payment order can only be issued for a receivable that has been properly served and has become final. If the tax notice was never served, or was served improperly, the receivable is not final, and this is examined in the payment order case under the ground that “no such debt exists”. For this reason, the first document examined in e-haciz files is often the service record of the tax notice.
The scope of the seizure is also subject to judicial review. Decisions stress that the “amount sufficient to cover the receivable” test in Article 62 does not give the administration unlimited discretion; seizing all of a debtor’s assets out of proportion to the debt is inconsistent with that test. The administration is expected to be able to explain which assets it seized and why.
For company debts, the liability of the legal representative (for example, a managing director) may also arise. Settled case law requires the administration to show concretely that the debt could not be collected from the company before turning to the representative. See the article on liability of legal representatives (in Turkish).
Practical points
In lifting a tax office seizure, the first few days often decide the outcome. The date of service of the payment order, whether the time to sue is still open and whether the seizure is proportionate to the debt determine which route to take. Payment, deferral, restructuring and litigation are not mutually exclusive; they often need to be considered together. For the options at the earlier penalty notice stage, see challenging tax penalties in Turkey.
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.
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