2026/3
Explanations Introduced by the Corporate Tax General Communiqué Serial No. 25
| Circular Type | English Tax Circular |
|---|---|
| Number | 2026/3 |
| Date | 01.06.2026 |
| Subject | Explanations Introduced by the Corporate Tax General Communiqué Serial No. 25 |
This circular explains the main corporate tax interpretation, filing, calculation and documentation topics addressed by Corporate Tax General Communiqué Serial No. 25.
1. Executive Summary
This circular explains the main corporate tax interpretation, filing, calculation and documentation topics addressed by Corporate Tax General Communiqué Serial No. 25.
2. Legal Background
The legal framework should be reviewed together with the relevant law, communiqué, presidential decree, secondary legislation, Revenue Administration guidance and official implementation announcements. The effective date, transitional provisions and the scope of taxpayers covered by the regulation must be analysed separately.
3. Taxpayers Potentially Affected
The regulation may affect resident companies, permanent establishments, multinational enterprise groups, financial institutions, holding companies, service companies, manufacturers, exporters, importers and other entities depending on their tax status, transaction profile and reporting obligations.
4. Corporate Tax Impact
Companies should assess whether the regulation changes taxable income, exemptions, deductions, carry-forward losses, withholding taxes, minimum tax computations, tax credits, advance tax calculations or annual corporate income tax return disclosures.
5. Accounting and Financial Reporting
Accounting teams should determine whether the change requires new ledger accounts, reclassification entries, deferred tax calculations, provision updates, reconciliation procedures or additional disclosures in statutory and management reporting.
6. Filing and Payment Calendar
All filing, notification, certification and payment dates should be entered into the internal tax calendar. Where an extension applies, companies should also document the original deadline, the revised deadline and the internal approval date.
7. Documentation Requirements
Tax positions should be supported by agreements, invoices, board resolutions, calculations, working papers, legal opinions, tax returns, electronic filing receipts and other relevant records.
8. Internal Control Considerations
A written control framework should assign responsibilities to tax, finance, accounting, legal, treasury, human resources and information technology teams where applicable.
9. Risk Assessment
Potential risks include late filing, underpayment, incorrect classification, insufficient documentation, inconsistent disclosures, tax inspection exposure, penalties and late payment interest.
10. Recommended Action Plan
Companies should identify affected transactions, appoint responsible teams, update internal procedures, complete technical calculations, obtain management approval and retain a complete audit trail.
11. Corporate Tax Return Preparation
The communiqué may affect the preparation of annual corporate tax returns, annexes, exemption schedules, deduction tables and reconciliation statements.
12. Domestic Minimum Corporate Tax
Companies should assess whether the communiqué contains explanations on the domestic minimum corporate tax base, exclusions, deductions and effective implementation.
13. Exemptions and Deductions
Participation exemption, foreign-source income, investment incentives, service export deductions, research and development benefits and other corporate tax advantages should be reviewed in light of the communiqué.
14. Inflation Accounting Interaction
Where relevant, the relationship between inflation adjustment differences, tax base determination and minimum tax calculations should be analysed.
15. Related Party Transactions
Transfer pricing, thin capitalisation and controlled foreign company disclosures should be reconciled with the corporate tax return.
16. Certification and Audit Files
Certified public accountant reports, schedules and supporting files should be prepared consistently with the communiqué explanations.
Frequently Asked Questions
What is English Tax Circular 2026/3 about?
Explanations Introduced by the Corporate Tax General Communiqué Serial No. 25
Who should review this circular?
Finance directors, tax managers, accounting teams, legal teams, certified public accountants, auditors and executives responsible for tax governance should review it.
Is this page an official legal opinion?
No. It is a general information page and does not replace the official legal text or professional tax advice.
What should companies do before implementation?
Companies should verify the final official text, identify affected transactions, document calculations, update internal controls and obtain professional advice where needed.
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