The minimum corporate tax will be applied to the earnings obtained in 2025 and the following taxation periods, and the earnings of the corporations subject to the special accounting period will be applied to the earnings obtained in the special accounting period starting in the calendar year 2025 and the following taxation periods.
The minimum corporate tax will not be applied for the corporations that start their activities for the first time for three accounting periods starting from the accounting period in which they start their activities.
-How will the domestic minimum corporate tax be calculated?
Commercial Profit in the Income Statement + KKEG – (exceptions and discounts stated below in Article 32/C) x 10%
Example:
Trading Profit 1.000.000 TL
Non-tax-deductible expenses 100.000TL
TAX BASE Before Exceptions: 1.100.000 TL
EXCEPTIONS
Turkish International Ship Registry Exemption: 200.000 TL
Emission Premium exemption: 100.000 TL
4691 R&D Earnings Exemption: 200.000 TL
Exemption for affiliate earnings: 100.000 TL
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TOTAL OF EXCEPTIONS 600.000 TL
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Minimum Corporate tax base: 500.000 TL
MINIMUM CORPORATE TAX RATE: 10%
MINIMUM CORPORATE TAX: 50.000 TL
If the corporate tax to be paid after deducting the deductions and exemptions other than those listed below, which can be deducted in the calculation of the company’s minimum corporate tax, is below the 50 Thousand TL in the above example, 50 Thousand TL will be paid as minimum corporate tax.
Domestic minimum corporate tax will also be applied for temporary tax periods. The provisions of this article will not be applied for three accounting periods starting from the accounting period in which the activities are started for the first time. Domestic minimum corporate tax is effective for the fiscal year 2025 and onwards.
-The following corporations will be subject to the minimum corporate tax.
a) Capital companies
b) Cooperatives
c) Public economic organizations
ç) Economic enterprises belonging to associations or foundations
d) Joint ventures
The following exemptions and deductions will not be taken into account in the calculation of the minimum corporate tax, in other words, they will be taken into account as deductions and exemptions in both calculations.
– Exemption for participation income obtained from full taxpayer corporations,
– Exemption for emission premium earnings
– Exempt earnings of investment funds and partnerships listed in subparagraph (d), except for the earnings obtained from the immovable properties owned
– Risturn exemption
– Exemption applied to earnings from sale leaseback transactions with financial leasing companies and asset leasing companies
– Exemption applied to earnings from the operation and transfer of ships registered in the Turkish International Ship Registry
– Earnings exemption under the Free Zones Law
– Venture capital fund deduction
– Protected workplace discount
– Law No. 4691 within the scope of the Technology Development Zones Law and R&D and design discounts that can be deducted from the corporate tax base
Article 32/C of the Corporate Tax Law
Domestic minimum corporate tax
(Article added by Article 36 of Law No. 7524; Effective: On the date of its publication to be applied to the earnings obtained in the year 2025 and the following taxation periods, and to the earnings obtained in the special accounting period starting in the calendar year 2025 and the following taxation periods of the institutions subject to the special accounting period)
Article 32/C
(1) The corporate tax calculated in accordance with the provisions of Articles 32 and 32/A cannot be less than 10% of the corporate income before deducting deductions and exemptions.
(2) While calculating the minimum domestic corporate tax, the following exemptions and deductions shall be deducted from the corporate income mentioned in the first paragraph
a) Exempt earnings listed in subparagraph (d), except for the earnings derived from the immovable properties owned by them under subparagraphs (a), (ç), (i), (j) and (k) of the first paragraph of Article 5,
b) Discounts within the scope of subparagraphs (g) and (h) of the first paragraph of Article 10,
c) Earnings exempted from tax under the Law No. 4490 dated 16/12/1999 on the Amendment of the Turkish International Ship Registry Law and the Decree Law No. 491 and the Free Zones Law No. 3218 dated 6/6/1985,
ç) R&D and design discounts that can be deducted from the corporate tax base with the exemption of earnings within the scope of Law No. 4691.
(3) From the domestic minimum corporate tax calculated within the scope of the first paragraph, the tax not collected due to the application of the reduced rate in accordance with the sixth, seventh and eighth paragraphs of Article 32 and the tax not collected in the relevant accounting period in accordance with the provision of Article 32/A due to the use of the investment contribution amounts in the incentive certificates obtained from the Ministry of Industry and Technology before the effective date of this article are deducted and the domestic minimum corporate tax to be paid is determined.
(4) The provisions of this Article shall also apply for temporary tax periods.
(5) The provisions of this Article shall not be applied for three accounting periods starting from the accounting period in which the activities are started for the first time.
(6) The expression “corporate income before deducting deductions and exemptions” in this Article refers to the amount found by adding the expenses not accepted by law to the commercial balance sheet profit at the end of the accounting period.
(7) The President of the Republic is authorized to reduce the rate stated in the first paragraph to zero or increase it up to one times, separately or together, by sectors, fields of activity, business lines or production areas, and the Ministry of Treasury and Finance is authorized to determine the procedures and principles regarding the implementation of the article.
Source: Corporate Tax LAw
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