**September 3, 2024, TUESDAY**
**Official Gazette Issue No: 32651**
**COMMUNIQUÉ**
**From the Ministry of Treasury and Finance (Revenue Administration):**
**GENERAL COMMUNIQUÉ ON TAX PROCEDURE LAW**
**(SERIAL NO: 564)**
**Authority**
**Article 1** – (1) The fourth paragraph of Article 5 of the Tax Procedure Law No. 213 dated 4/1/1961 states: “The Ministry of Finance may disclose the declarations of taxpayers that serve as the basis for tax assessment, the finalized taxes and penalties, as well as unpaid taxes and penalties despite their due dates. The Ministry of Finance may delegate this authority locally. In addition, information and documents requested in connection with judicial and administrative investigations conducted by public officials and information related to tax collection by banks may be provided. The procedures and principles regarding the provision of this information are determined by the Ministry of Finance. The notification of professional organizations established by law and chambers of professions established under Law No. 3568 about those who have been found to issue or use false or misleading documents based on tax audit reports is not considered a violation of tax confidentiality. In this case, the persons and institutions receiving the information must also comply with the prohibitions stated in this article. The Ministry of Finance is authorized to determine the procedures for the disclosure of information.” In accordance with this provision, the procedures for disclosing finalized taxes and penalties due to assessments made by way of supplementary, ex officio, or administrative tax assessments, as well as unpaid taxes and penalties despite their due dates, were determined by the General Communiqué on Tax Procedure Law (Serial No: 293), published in the Official Gazette dated 27/1/2001 and numbered 24300.
**Disclosure Procedure**
**Article 2** – (1) Pursuant to the authority granted to the Ministry of Treasury and Finance under the fourth paragraph of Article 5 of Law No. 213:
a) The disclosures to be made in 2024 will be posted at the tax offices across Turkey by being displayed on the notice boards of the tax offices from October 15, 2024, to October 31, 2024 (inclusive) and on the Revenue Administration’s website from November 1, 2024, to November 15, 2024 (inclusive).
b) The disclosure will include taxpayers with a debt of 5,000,000 TL or more or with finalized taxes and penalties amounting to this or more for each tax office.
c) The disclosure will consider taxes and penalties that, as of December 31, 2023, were due but remained unpaid as of September 30, 2024, and the taxes and penalties identified for disclosure as specified in the General Communiqué on Tax Procedure Law (Serial No: 293), as well as those finalized between June 1, 2023, and May 31, 2024.
d) The disclosed information, the location of disclosure, and other related matters must comply with the principles set out in the General Communiqué on Tax Procedure Law (Serial No: 293). However, for the purposes of the “Disclosure on the Internet” section (III/B) of the same Communiqué, it is deemed appropriate for provincial treasury offices to electronically send the lists prepared under section (I-A) of the General Communiqué on Tax Procedure Law (Serial No: 293) to the Revenue Administration’s Directorate of Revenue Management (IV) and the lists prepared under section (I-B) to the Revenue Administration’s Directorate of Collection and Disputed Affairs, along with an official letter.
**Exclusions from Disclosure**
**Article 3** – (1) The following will be excluded from the disclosure:
a) Claims with due dates on or before December 31, 2004, that were subject to offset and set-off applications accepted under the temporary Article 3 of the Metropolitan Municipality Law No. 5216 dated 7/10/2004 and the temporary Article 5 of the Municipal Law No. 5393 dated 7/3/2005, concerning metropolitan municipalities, municipalities, their affiliates, and companies with more than 50% of their capital owned by metropolitan municipalities/municipalities.
b) Claims with due dates on or before December 31, 2004, related to metropolitan municipalities, their affiliates, and the local government unions consisting of member municipalities, which did not previously enter into reconciliation under the temporary Article 3 of Law No. 5216, but submitted an application under Article 167 of the Law on the Restructuring of Certain Receivables and Amendments to the Social Insurance and General Health Insurance Law and Other Laws and Law Decrees No. 6111, dated 13/2/2011.
c) Claims structured under the first paragraph of the temporary Article 2 of the Law on Amendments to the Labor Law and Certain Laws and Decrees and Restructuring of Certain Receivables No. 6552, dated 10/9/2014.
ç) Claims structured under the Law on Restructuring Certain Receivables No. 6736, dated 3/8/2016.
d) Claims structured under the Law on Restructuring Certain Receivables and Amendments to Certain Laws and a Law Decree No. 7020, dated 18/5/2017, including those within the scope of Article 5 of the Law.
e) Claims structured under the Law on Restructuring of Taxes and Other Certain Receivables and Amendments to Certain Laws No. 7143, dated 11/5/2018, including those within the scope of Article 11 of the Law.
f) Claims structured under the Law on Restructuring Certain Receivables and Amendments to Certain Laws No. 7256, dated 11/11/2020.
g) Claims structured under the Law on Restructuring Certain Receivables and Amendments to Certain Laws No. 7326, dated 3/6/2021.
ğ) Claims structured under the Law on Restructuring Certain Receivables and Amendments to Certain Laws No. 7440, dated 9/3/2023.
(2) It is deemed appropriate not to include in the disclosure the finalized taxes and penalties of taxpayers with tax liability (income tax or corporate tax) as of the date of the earthquake in the provinces of Adana, Adıyaman, Diyarbakır, Elazığ, Gaziantep, Hatay, Kahramanmaraş, Kilis, Malatya, Osmaniye, and Şanlıurfa, as well as Gürün district of Sivas, which were affected by the earthquakes that occurred in Kahramanmaraş on February 6, 2023, and declared as a force majeure. This also applies to their branches with tax liabilities. However, only the finalized taxes and penalties related to these tax liabilities will be excluded from the disclosure.
**Effective Date**
**Article 4** – (1) This Communiqué enters into force on the date of its publication.
**Execution**
**Article 5** – (1) The provisions of this Communiqué shall be executed by the Minister of Treasury and Finance.
Source: Official Gazette
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