In the report dated 1/9/2026, following the examination of (C) Ltd. Şti’s activities for the 2025 fiscal period under the scope of issuing fraudulent documents, it was determined that the act of “Issuing Fraudulent Documents” in the name of the taxpayer company was carried out by company manager Mr. (Ç), who earned commission income as a result of this action. It was concluded that retroactive tax liability should be established for Mr. (Ç), who does not have a current tax obligation, and an income tax assessment of 1,000,000 TL should be made for the 2025 tax year based on the commission income earned from the fraudulent document trade.
Accordingly, due to the violation specified in Article 359 of Law No. 213, a tax loss penalty increased by 50% must be imposed, totaling 4.5 times the assessed tax. Thus, a tax loss penalty of 4,500,000 TL (1,000,000 TL x 4.5) will be imposed on Mr. (Ç).
1) Article 11 of Law No. 7524 amended Article 353 of Law No. 213, which regulates special irregularity penalties, to add Table (2) below. This amendment stipulates that special irregularity penalties will be applied in increasing amounts for each determination.
Table 2
| Determination Number | Penalty Amount for Clause (1) of the First Paragraph of Article 353 (Minimum-TL) | Penalty Amount for Clause (2) of the First Paragraph of Article 353 (TL) |
|---|---|---|
| 2nd Determination | 20,000 | 20,000 |
| 3rd Determination | 30,000 | 30,000 |
| 4th Determination | 40,000 | 40,000 |
| 5th Determination | 50,000 | 50,000 |
| 6th and Subsequent Determinations | 100,000 | 100,000 |
Source: Revenue Administration https://www.gib.gov.tr/node/178463
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