Recent Developments
Pursuant to Presidential Decree No. 11396, published in the Official Gazette dated 6 June 2026 and numbered 33272, Türkiye has become a signatory to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (“GIR-MCAA“), enabling the automatic exchange of GloBE Information Returns (“GIR“) between Türkiye and other jurisdictions that are party to the agreement. Accordingly, where the GIR is filed in a jurisdiction that is a party to the agreement, Constituent Entities in Türkiye will not be required to file the GIR locally and will only submit the relevant notification form.
In this legal alert, we highlight the key implications of Türkiye’s approval to the GloBE Information Exchange MCAA.
GIR Filing Requirements and Notification Mechanism
A. Framework under the GloBE Rules[1]
Under Article 8.1.1 of the GloBE Rules, each Constituent Entity in an implementing jurisdiction must file a GIR with the local tax administration.
However, to reduce compliance burdens, local filing is not required where the GIR is filed by the Ultimate Parent Entity (“UPE“) or a Designated Filing Entity (“DFE“) in a jurisdiction that has a Qualifying Competent Authority Agreement (“QCAA“) in effect with the local jurisdiction for the relevant fiscal year.
If a GIR is not being filed locally, the Constituent Entity will notify the tax administration from which jurisdiction it will receive the GIR under a QCAA.
B. Local Implementation under Turkish Tax Legislation[2]
In line with OECD practices, the Turkish Revenue Administration has introduced reporting templates.
Within this framework, constituent entities located in Türkiye that are members of in-scope multinational enterprise groups—despite not being direct taxpayers of the Global Minimum Top-up Tax—are required to submit the “Notification Form on the Global Minimum Top-up Tax” during the filing period.
In addition, where the GIR has not been filed either in Türkiye or in another jurisdiction that is a party to the GIR-MCAA, such constituent entities are also required to complete the “General Information Form on the Multinational Enterprise Group” attached to the notification form.
C. Implications of Türkiye’s Becoming a Signatory to the GIR-MCAA
Following Türkiye’s accession to the GIR‑MCAA, a Constituent Entity in Türkiye is not required to file the GIR locally if it is filed in a signatory jurisdiction.[3]
In such cases, the entity is only required to submit the Notification Form on the Global Minimum Top-up Tax, through which the Turkish Tax Authority is informed of the jurisdiction from which it will obtain the GIR via information exchange mechanisms.
Furthermore, the General Information Form will not need to be completed, as the relevant information will already be provided through the GIR exchanged under the GIR‑MCAA framework.
Conclusion
As Türkiye has become a signatory to the GIR-MCAA, it is essential to ensure that the GIR is filed in a jurisdiction listed among the agreement’s signatories. Where this condition is met, constituent entities in Türkiye are only required to submit the Notification Form on the Global Minimum Top-up Tax, as the Turkish Tax Authority will obtain the relevant information through exchange mechanisms. In cases where the GIR is not filed in a jurisdiction listed among the agreement’s signatories, additional compliance obligations may arise, including the requirement to file the GIR locally and to submit the General Information Form on the Multinational Enterprise Group.
[1]OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return, section “Notification that the GIR will be received under Exchange of Information”
[2] Gelir İdaresi Başkanlığı
[3] Signatories of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA)
