Filing Obligations: The Global Top-up Tax Return, the GIR, and the Notification Form
Under Pillar 2, you may have a filing obligation even if you owe no tax. Which form is filed by whom is the most commonly confused aspect of implementation.
Why Does It Matter?
No tax arising and no filing obligation arising are not the same thing. An in-scope group's affiliate in Türkiye may end up owing no tax at all, yet still be required to file a notification. An unfiled form is detected far more easily than unpaid tax.
Four Documents
Global Minimum Top-up Corporate Tax Return — The principal return that gives rise to the assessment and accrual of the tax.
Global Minimum Top-up Corporate Tax Information Return (GIR) — A comprehensive information set showing the group's structure, jurisdictional calculations, safe harbour elections, and top-up tax results. Under certain conditions it may be filed by an entity authorized on behalf of the group, and may be shared between jurisdictions under applicable information-exchange arrangements.
Notification Form for Global Minimum Top-up Corporate Tax — Filed by Türkiye-based entities that are not themselves taxpayers but are affiliated with an in-scope group.
General Information Form on the Multinational Enterprise Group — An annex to the notification form containing general information on the group's structure.
Drafts of these documents were made available to taxpayers by the Revenue Administration via the Digital Tax Office on 8 April 2026.
Timeline
The local return deadline for the 2024 fiscal year was first extended from 31 December 2025 to 15 January 2026, and then to 28 January 2026. The deadline for the global return was moved from 30 June 2026 to 31 July 2026 by Circular No. VUK-203/2026-9 dated 26 June 2026.
How Should Filing Responsibility Be Allocated?
Having one group entity prepare the filing, or outsourcing it to a third party, does not automatically transfer the statutory taxpayer's responsibility. Where there is more than one affiliated entity in Türkiye, the entity that will assume the filing and information-reporting obligation must be designated, and it must be confirmed in writing that the other entities have been included in scope and their data verified.
Where reliance is placed on an information return being filed in a foreign jurisdiction, the existence of a qualifying competent authority agreement in force for the relevant period between that jurisdiction and Türkiye, and the practical availability of information exchange, must be checked. The absence of such an agreement, a failure to share information in time, or a foreign return that does not cover all Türkiye-based entities can affect the local notification obligation.
Points to Note
"Group headquarters is handling the filing."
The fact that group headquarters files an information return in its own jurisdiction does not mean the Türkiye-based entity has nothing to do in every case. Whether a qualifying agreement enabling information exchange with the relevant jurisdiction is in force, whether the information is actually transferred to Türkiye, and the local notification requirements must be separately checked. The defense of "headquarters was handling it" is not, on its own, sufficient against a procedural penalty.
Action Items
- Determine and document in writing which entity will file which document for every group company in Türkiye
- Complete Digital Tax Office access and authorizations in advance
- Get the 2025 fiscal-year timeline moving now — the local filing deadline of 31 December 2026 is not far off
- Do not rely on further extensions; there is no guarantee an extension will be granted every year
- If relying on an information return filed by group headquarters, confirm that the information-exchange agreement with the relevant jurisdiction is in force
Conclusion
Who bears the filing obligation and which document is required varies by group structure. Preparing a written obligation map for each entity in Türkiye — showing the document type, the responsible party, the data source, the deadline, and the approving authority — is one of the most important controls in the process.