Amended Return or Defence after a KURGAN Letter in Turkey 2026: Correcting Fake Invoices on Your Own Initiative, Voluntary Disclosure (TPL Art. 371), Filing Under Reservation, Defending Without Correction, Partial Correction, Council of State Case Law and Three Model Texts

For a company in Turkey that receives a KURGAN information request or an Examination Preparation Letter from the Tax Inspection Board, the costliest decision is whether to remove the flagged invoices from its records by filing amended returns, or to defend the transactions as genuine. The letters rest on the duty to provide information in Tax Procedure Law (TPL) Art. 148; they do not impose a duty to correct. There are four routes for the same invoice: an amended return on the company’s own initiative, an amended return with voluntary disclosure under TPL Art. 371, an amended return under reservation, and a defence without any correction. Each has different consequences for the tax loss penalty, the criminal exposure under TPL Art. 359, the right to sue, VAT and corporate tax, and the likelihood of an examination. Tax declared without reservation cannot be challenged in court (TPL Art. 378(2)). Voluntary disclosure is the only route that removes both the penalty and the application of Art. 359, and the administration’s position is that it is not available for the subject of an Examination Preparation File, a position that tax lawyers contest. This guide explains each route with the relevant Council of State and Constitutional Court decisions, a worked example and three model texts. It reflects the law in force on 27 October 2026.

Short answer: correction is a choice, not a duty

KURGAN information requests and Examination Preparation Letters rest on the administration’s power to request information. Under TPL Art. 148, public bodies, taxpayers and persons dealing with taxpayers must provide the information requested by the Ministry or by those authorised to conduct tax examinations. The provision imposes a duty to provide information. It does not impose a duty to correct a return. The administration’s own documents point the same way: the Board’s position is that information requests do not ask the taxpayer to correct its returns, but that taxpayers who do correct may be removed from examination plans.

A choice is meaningful only when its consequences are known. According to the first results announced by the Tax Inspection Board on 23 October 2026, 1,900 of the 5,543 taxpayers sent an Examination Preparation Letter filed amended returns and removed invoices of about TRY 23.4 billion from their records, while 622 submitted explanations and documents without correcting. Both routes were taken by a significant number of companies. Which one is right depends on the invoice.

Four routes, four outcomes

The table sets out the four routes for the same flagged invoice side by side. The conditions and the case law behind each cell are explained in the sections that follow.

No route is right for every invoice. Defending an invoice for goods that were never received leaves the company facing the threefold penalty and its managers facing a criminal investigation. Correcting an invoice for goods that were actually received from the issuer, with a sound document chain, gives up a right to deduct that the company holds, when nothing requires it to. The right route is chosen invoice by invoice.

Route 1: amended return on the company’s own initiative

An own-initiative correction means filing an amended return that removes the VAT on the flagged invoices from the deduction, without a voluntary disclosure request and without a reservation. Four technical consequences should be calculated before the return is filed.

Which periods, and how many returns?

The amended return is filed for the period in which the VAT on the invoice was deducted. If VAT was carried forward after that period, the carried-forward amount changes and later periods are affected too. Section 7.3 of the Revenue Administration’s VAT Circular No. 60 states that all returns in between must then be corrected, but that where the correction produces no payable tax in the intermediate periods, separate returns for each period are not required and returns for the corrected period and the latest period are sufficient. Where the company has claimed VAT refunds in the intermediate periods, the carried-forward amount matters for the refund calculation, and the administration’s rulings require a separate amended return for each period (Istanbul Tax Office Directorate ruling no. 39044742-KDV.11-954 of 2 July 2013).

Payment: late payment interest

Tax arising from an own-initiative amended return is paid with late payment interest under TPL Art. 112(3). The interest is calculated at the late-payment surcharge rate set under Law No. 6183 Art. 51, and fractions of a month are disregarded. That rate has been 3.7% per month since Presidential Decision No. 10556 (Official Gazette, 13 November 2025). A company with sufficient carried-forward VAT may find that the correction reduces the carried-forward balance without producing tax to pay; the cash effect then appears in later periods.

Penalty: the 50% rule and the threefold question

Under TPL Art. 344(3), the tax loss penalty for returns filed after the statutory deadline is applied at 50%, except for returns filed after a tax examination has begun or the matter has been referred to an assessment commission. The Revenue Administration’s guide on voluntary disclosure (August 2024) also states that where amended returns are filed late on the taxpayer’s own initiative, or the disclosure conditions are breached, a tax loss penalty of only 50% of the lost tax is imposed.

How that rule combines with the threefold penalty for the acts in Art. 359 (TPL Art. 344(2)) is contested. In decision E.2021/3928, K.2023/479 of 1 March 2023, the Council of State’s Ninth Chamber upheld a regional court judgment concerning a company that had removed some invoices by amended returns before an examination and was later found to have used them knowingly. The regional court held that the threefold penalty was to be applied at 50%, that is, at one and a half times the tax. That is one decision, and the point remains open.

Returns filed after an examination has begun are treated differently. In decision E.2024/559, K.2024/974 of 23 October 2024, the Council of State’s Plenary Tax Chambers held unanimously that where amended returns were filed after an examination of the same matter had begun, the conditions in TPL Arts. 30(4) and 344(3) were not met. The assessment then had to follow the examination report, and tax and 50% penalties charged on the amended returns were unlawful. The decision to correct should therefore be taken before any notice of examination.

The price in terms of the right to sue

Under TPL Art. 378(2), taxpayers cannot sue against the bases they have declared or the tax assessed on them. In decision E.2020/250, K.2020/401 of 11 March 2020, adopted by majority, the Plenary Tax Chambers held that tax arising from late amended returns filed without a reservation could not be challenged in court, while the tax loss penalty and late payment interest, which are not barred, remained subject to judicial review. A company that corrects on its own initiative therefore largely gives up the possibility of recovering the tax later.

Corporate tax and provisional tax

The VAT correction is only one side of the problem. If the invoice amount was recorded as an expense or cost, the corporate tax base may also be affected, and two situations must be distinguished. If the goods or services were never received, there is no expense either, and the corporate tax return also has to be considered. If the goods were actually received but the invoice came from a company interposed between the real seller and the buyer, the position differs. In decision E.2023/7867, K.2024/670 of 19 February 2024, the Council of State’s Third Chamber held unanimously that VAT deduction requires the goods or services to have been bought from the issuer of the invoice, but that because corporate tax is levied on net corporate income (Corporate Tax Law Art. 6), a real expense may be accepted as a cost even without a document. In such files, the VAT deduction can be corrected while the cost is defended for corporate tax.

For provisional tax, Income Tax Law supplementary Art. 120 provides that provisional tax which can no longer be set off is not collected as tax, but the related late payment interest and penalty are collected. The corporate tax effect should be calculated together with the VAT correction, because the two returns tell the same story about the same purchase.

Route 2: voluntary disclosure (TPL Art. 371)

Voluntary disclosure is the only mechanism that can close the tax and the criminal side of a fake invoice file at the same time. Under TPL Art. 371, taxpayers who commit acts giving rise to a tax loss penalty in taxes based on returns, and those who take part in them, are not penalised if they disclose their unlawful conduct to the relevant authorities on their own initiative by petition and meet the conditions listed. TPL Art. 359 provides that it does not apply to those who report the situation to the relevant authorities in compliance with the conditions of Art. 371. The Revenue Administration’s voluntary disclosure guide reads the two provisions together: disclosure is available to those who committed evasion offences, and no criminal complaint is made against taxpayers who meet the conditions.

Disclosure is now made electronically. The voluntary disclosure guide states that a return showing that it contains a disclosure request is treated as a disclosure return, so a separate petition is not strictly required. In a fake invoice file, however, it is useful to file a petition with the tax office on the same day, recording the scope of the request and the invoices concerned; a model is given below. The surcharge is calculated for each month or part of a month at the Law 6183 Art. 51 rate, currently 3.7% per month. The guide also states that disclosure is not available for VAT that a taxpayer removes from its deductions after an invitation to remedy a negative finding in a VAT refund procedure, or for the subject of a preliminary finding letter under TPL Art. 370(b).

When does the door close? The “detection” debate

The words that decide the fate of disclosure in a fake invoice file are in the parenthesis of Art. 371(2): for acts constituting evasion offences, the disclosure must be made before the commission of the act is detected. That moment can come earlier than the start of an examination, which is the test for ordinary tax loss.

The administration’s view is set out in its guide to the Examination Preparation File: voluntary disclosure is not available for the subject of the file, although an amended return may still be filed. On that view, a company that has received an Examination Preparation Letter cannot obtain disclosure for the invoices it lists.

Tax lawyers have contested that view on several grounds. An Examination Preparation Letter is, on the administration’s own description, an information request, and an information request is not one of the events that close disclosure under Art. 371. A report about the seller’s issuing of fake documents is not a detection that the buyer used fake documents. The VAT General Implementation Communiqué itself provides that, absent a separate finding or report about the document the buyer used, the buyer is not to be treated as a user of fake documents merely because it bought from a person about whom a fake document report exists (section IV/A2-3.5). Finally, Article 73 of the Constitution requires tax obligations to be set by law, and it is argued that a guide cannot narrow a right granted by statute. The question has not been settled by the courts.

Two practical consequences follow. If disclosure is to be attempted, it should be made at the earliest possible moment after the letter is served. And the petition should not read as a confession that the company knowingly used fake documents. It should state, in measured terms, that the right to deduct has become disputed because of the finding about the seller and that the returns are being corrected for that reason. The petition will be one of the first documents a prosecutor reads if a criminal file is ever opened.

Route 3: amended return under reservation

A reservation (ihtirazi kayıt) is a statement by which the taxpayer files the return but declares that it does not accept its content and preserves its right to sue. The Tax Procedure Law contains no provision on reservations. They were developed by Council of State case law as an exception to the bar in TPL Art. 378(2), and Administrative Procedure Law Art. 27(4) recognises them indirectly by providing that suits against taxes assessed on returns filed under reservation do not suspend collection. According to the Plenary Tax Chambers, a reservation must be written on the return, noted on the accrual slip, or made by a petition filed with the tax office no later than the date on which the return is filed (E.2020/250, K.2020/401).

The line drawn by the courts: the coercive letter

In fake invoice files, the value of a reservation depends on the circumstances in which the amended return was filed. In application no. 2015/15100, decided on 27 February 2019, the Constitutional Court found a violation of the right to property where courts had dismissed, without examining the merits, actions against taxes assessed on amended returns that the taxpayers had filed under reservation after a tax office letter requiring correction and warning of consequences. Following that decision, the Plenary Tax Chambers held that in such cases the courts must examine whether the invoices reflected real supplies of goods or services (E.2020/522, K.2020/606 of 22 May 2020), relying on TPL Art. 3 and VAT Law Art. 29.

The Plenary Tax Chambers have kept that line narrow. Where a taxpayer added a reservation on its own initiative, without any coercive letter from the administration, the reservation did not give a right to sue against the tax; only the penalty and the late payment interest could be reviewed (E.2023/1742, K.2024/215 of 27 March 2024, unanimous). They have also held, by majority, that a reservation placed on a return filed with a voluntary disclosure request is invalid: disclosure requires an unconditional notification made without outside pressure, while a reservation makes the return conditional (E.2019/1545, K.2020/283 of 11 March 2020). Voluntary disclosure and a reservation therefore cannot be combined on the same return.

Is a KURGAN letter a coercive letter?

The courts have not yet answered this question. The administration describes KURGAN letters as information requests under TPL Art. 148 that are not coercive, and its guide to the Examination Preparation File says only that nothing prevents an amended return from being filed. On that basis, the administration can argue that returns filed under reservation after such a letter were filed on the taxpayer’s own initiative. On the other side, the letter identifies the invoices, and asks whether they were recorded, whether their VAT was deducted and whether amended returns were filed. Those are strong facts suggesting that any correction was prompted by the administration. In decision E.2025/4341, K.2025/5658 of 17 December 2025, adopted by majority, the Council of State’s Third Chamber treated a deficiency letter issued in the VAT refund procedure of the claimant’s customer, which referred to findings about the claimant, as having compelled the claimant to file amended returns, and held that its reservation gave a right to sue. A company correcting under reservation should therefore name the letter and its date of service expressly in the reservation text.

Deadline, collection and examination

An action against tax accrued on a return filed under reservation is brought in the tax court within 30 days (Administrative Procedure Law Art. 7). For returns filed electronically, electronic transmission of the accrual slip counts as service (TPL Art. 28). Because views differ on the starting day, counting the period from the day after the return is filed is the safest approach. The action does not suspend collection (Administrative Procedure Law Art. 27(4)): the tax is paid and recovered if the case is won. According to the Ministry’s progress report, in one past monitoring programme the taxpayers who filed under reservation were referred for examination to resolve the inconsistency in their returns. Correction under reservation therefore combines paying the tax now with the prospect of an examination. It suits a company that believes the supply was real, wants to pay for reasons such as a pending VAT refund or commercial standing, and is prepared to pursue recovery in court.

Route 4: defending without correction

The fourth route is to leave the invoice in the records, keep the VAT deduction and reply to the letter with explanations and documents showing that the transaction was real. In the Board’s first results, 622 taxpayers took this route. Its legal basis is TPL Art. 3/B: in taxation, the real nature of the taxable event is decisive and may be proved by any evidence other than an oath. VAT Law Art. 29 ties the deduction to the VAT shown on invoices issued for supplies made to the taxpayer; if the transaction was real, the right to deduct exists.

The strength of this route is limited by the strength of the document chain. The Tax Inspection Board’s circular of 18 April 2025 requires the inspector first to establish whether the goods or services were actually received and, if so, to assess against thirteen objective criteria whether a document not belonging to the real seller was used knowingly. The order, the delivery and transport documents, the goods receipt, the warehouse entry, the bank payment and the use of the goods in production or resale are each concrete facts to set against a criterion. How the criteria work is explained in our main guide on fake invoice allegations and KURGAN tax audits.

The risk is plain. If the defence does not satisfy the risk analysis, an examination for use of fake documents is opened. According to the Ministry’s progress report, knowing use was found for 72 of the 154 buyers whose examinations were completed in current-period audits generated by KURGAN, about 47%. Where the defence is strong, however, even a denied deduction leaves the company with a file that can be argued in the tax court and with its right to sue intact.

Partial correction, invoice by invoice

The right answer may be neither wholesale correction nor wholesale defence. For invoices from the same seller, the delivery documents, payments and records of use may be complete for some and broken for others. A finding about the seller does not make every invoice it issued fake: the VAT General Implementation Communiqué provides that the buyer is not to be treated as a user of fake documents merely because a report exists about the seller (section IV/A2-3.5), and in cases that reach court the question is whether each invoice reflects a real supply (Plenary Tax Chambers E.2020/522, K.2020/606). An invoice-by-invoice review avoids paying tax that is not owed and makes the defended invoices more credible.

The danger of partial correction is inconsistency. If the company corrects one invoice from a seller and defends another, it should explain why. An unexplained partial correction can be read as “the company knew which invoices were problematic” and makes the intent assessment harder for the invoices it defends. The line between corrected and defended invoices should be drawn on a documented criterion that can be repeated, such as complete delivery and payment records. A model explanation is given in the model texts below.

Worked example: one invoice, seven outcomes

Assume a company deducted TRY 200,000 of VAT shown on a purchase invoice with a base of TRY 1,000,000 at the 20% rate, and that there is no carried-forward VAT, so correction produces tax to pay. The table shows only the tax and the tax loss penalty. Late payment interest, the disclosure surcharge, corporate tax and litigation costs are left out. The figures are illustrative; each file needs its own calculation.

The range runs from zero to TRY 800,000 for the same invoice. Where the defence has a good chance of success, the expected outcome moves toward the lower end; where the goods were never received, it moves toward the upper end, and disclosure, or at least correction before an examination, becomes markedly cheaper. The Art. 376 reduction requires the company to apply within 30 days of service of the assessment and to pay the tax and the remaining penalty; a company that sues loses the reduction (TPL Art. 376).

Side effects: compliant taxpayer discount and VAT refunds

The effect of the decision is not confined to the invoice. Under Income Tax Law supplementary Art. 121, compliant taxpayers may deduct 5% of their annual income or corporate tax from the tax payable, up to TRY 12,000,000 for returns filed from 1 January 2026. Amended returns filed late to correct a return that was filed on time, or filed with voluntary disclosure, do not breach the timely filing condition, but the tax accrued on the relevant returns must have been paid. Those found to have committed the acts in TPL Art. 359 in the year for which the discount is calculated or in the previous four calendar years cannot use the discount. A finding of knowing use can therefore cost not only the threefold penalty but the discount over five consecutive years. There is no express administrative statement on whether an own-initiative correction counts as a finding that an Art. 359 act was committed for this purpose.

For exporters and manufacturers claiming VAT refunds the position is more sensitive. A negative finding about a supplier slows the refund, and the voluntary disclosure guide states that disclosure is not available for VAT removed from the deductions after an invitation to remedy the negative finding. At the same time, the VAT General Implementation Communiqué provides that, without a separate finding or report about the document the buyer used, the buyer is not treated as a user of fake documents merely because it bought from a person about whom such a report exists.

The criminal side: does an amended return close the file?

Paying the tax does not by itself remove the criminal risk. Under TPL Art. 359, a person who uses a fake document faces three to eight years’ imprisonment, and a person who uses a document that is misleading in content faces eighteen months to five years. The only route that certainly removes that exposure is a disclosure that meets the conditions of Art. 371, to which Art. 359 refers. An amended return filed without meeting those conditions does not, by the wording of the statute, prevent Art. 359 from applying.

Prosecution, however, depends on a procedure set by law. Under TPL Art. 367, tax inspectors report evasion offences to the public prosecutor with the opinion of the report evaluation commission, and a public case cannot be filed until that notification is made. Communiqué No. 306 on the Tax Procedure Law provides that no tax crime report is prepared and no criminal complaint is made for taxpayers found to have used a fake document without knowing it. According to the Ministry’s progress report, in one past monitoring programme taxpayers who corrected without reservation were removed from the examination plans for fake document use, and a tax crime report can only follow an examination. Correction therefore reduces the criminal risk in fact, not in law. That reduction is not a guarantee, particularly where an informant’s report or an investigation about the company already exists from another source.

If an examination is opened and a tax crime report is prepared, the effective repentance rules in Art. 359 apply. If the tax assessed, all late payment interest and surcharge, half of the penalties and the related surcharge are paid during the investigation stage, the prison term is reduced by half; if paid during the prosecution stage before judgment, by one third. The items to be paid, the effect of the stage and the relationship with the tax case are explained in our guide on effective repentance in Turkish fake invoice cases. Acts committed over several calendar years in pursuit of the same decision are treated as a continuing offence (Criminal Code Art. 43, applied through Art. 359). What a manager should do if summoned is explained in our guide on giving a statement in a Turkish fake invoice investigation, and the personal exposure of directors in our guide on personal liability of directors and managers.

Ten questions before deciding

1. Is the letter a KURGAN information request, an Examination Preparation Letter from the Board’s presidency, or a letter from an inspector after notice of examination?
2. When does the reply period end, and is a reasoned request for more time needed?
3. Is there an informant’s report, a preliminary finding letter or an invitation to remedy a negative VAT refund finding concerning the company?
4. For each invoice, were the goods or services actually received, and if so, from whom?
5. Which delivery, receipt, warehouse, payment and use records are complete, and which are missing?
6. In which period was the VAT on each invoice deducted, and is there carried-forward VAT or a refund claim in later periods?
7. Were the invoices recorded as an expense or cost, and what is the corporate tax and provisional tax effect?
8. If correcting, will it be with voluntary disclosure, on the company’s own initiative or under reservation, and is the effect of that choice on the right to sue understood?
9. Are the reply, the rationale for correction and the petitions consistent with what the managers could say in a statement?
10. Have the side effects on the compliant taxpayer discount and on VAT refunds been calculated?

Model texts

The three models below are English working drafts for group review. The texts filed with the tax office or the Tax Inspection Board must be in Turkish and rewritten for the facts of each file. Where the company may still defend the transactions as real, every sentence must be consistent with any later statement to a prosecutor and with any tax court petition.

Model 1: voluntary disclosure petition

Model 2: reservation petition filed with amended returns

The petition should be filed on the same day as the returns. If the reservation field of the electronic return is also used, its wording should refer to the letter and its date of service as well.

Model 3: explanation for a partial correction

The line drawn in the third model rests on delivery and payment records. In another file a different criterion may be decisive. What matters is that the line between corrected and defended invoices is drawn on a documented criterion that can be repeated.

How Hukukçular Evi can help

Hukukçular Evi Ankara reviews each invoice flagged in a KURGAN or Examination Preparation Letter, sets out the tax and criminal consequences of correction, disclosure, reservation or defence for each one, drafts the disclosure and reservation petitions and the rationale for a partial correction, builds the reply to the Tax Inspection Board around the document chain, represents the company during the examination and the assessment, and brings the tax court action where needed. We work in English with foreign-owned companies and group finance and legal teams. The scope of the service is described on our fake invoice defence page (in Turkish), and the lawyer’s profile is on the author page. You can reach us on +90 554 648 37 15 before any return is filed.

Frequently asked questions

A KURGAN letter arrived. Must we remove the invoices from our records?

No. The letter is an information request under TPL Art. 148, which imposes a duty to provide information, not to correct. Correction is a choice and should be made with its consequences known, invoice by invoice.

If we file amended returns, will a tax loss penalty be imposed?

Not if the voluntary disclosure conditions are met. Without disclosure, for returns filed before an examination begins, the penalty is applied at 50% (TPL Art. 344(3)); how that combines with the threefold penalty is contested. After an examination begins, the 50% rule does not apply (Plenary Tax Chambers E.2024/559, K.2024/974).

Is voluntary disclosure still possible after an Examination Preparation Letter?

The administration’s guide states that it is not available for the subject of the file. That view is contested because an information request is not among the events listed in TPL Art. 371. After a notice of examination, disclosure is closed by the statute itself.

How much is the voluntary disclosure surcharge?

It is calculated for each month or part of a month at the late-payment surcharge rate in Law No. 6183 Art. 51, which has been 3.7% per month since Presidential Decision No. 10556 (Official Gazette, 13 November 2025).

Can we sue against our own amended return?

Not against the tax on a return filed without reservation (TPL Art. 378(2)); the penalty and interest can be challenged. A reservation after a coercive letter from the administration gives a right to sue against the tax; a reservation added on the company’s own initiative does not.

Can we file a disclosure return under reservation?

You can write the reservation, but it will not be valid. The Plenary Tax Chambers held by majority that a reservation on a return filed with voluntary disclosure is invalid and that an action against the tax on it must be dismissed (E.2019/1545, K.2020/283).

What is the deadline to sue against a return filed under reservation?

Thirty days in the tax court (Administrative Procedure Law Art. 7). For electronic returns, transmission of the accrual slip counts as service (TPL Art. 28), so counting from the day after filing is the safest approach.

Does the action stop collection?

No. Actions against taxes accrued on returns filed under reservation do not suspend collection (Administrative Procedure Law Art. 27(4)). The tax is paid, and refunded if the case is won.

We have carried-forward VAT. Must we amend every month?

Under section 7.3 of VAT Circular No. 60, if no tax becomes payable in the intermediate periods, returns for the corrected period and the latest period are sufficient. Where refunds were claimed in intermediate periods, the administration requires a separate amended return for each period.

The goods were real but came through another company. What then?

VAT deduction requires the goods to have been bought from the issuer of the invoice. For corporate tax, the Council of State’s Third Chamber held that a real expense may be accepted as a cost even without a document (E.2023/7867, K.2024/670). VAT and corporate tax should be assessed separately.

Does correcting end the criminal risk?

Not in law. Only a disclosure meeting the conditions of TPL Art. 371 removes the application of Art. 359. Because prosecution depends on a tax crime report and opinion (TPL Art. 367), correction reduces the risk in fact but gives no guarantee.

What happens to the compliant taxpayer discount?

Late amended returns correcting a return filed on time do not breach the timely filing condition, but the tax accrued must be paid. A finding that an Art. 359 act was committed in the year concerned or the previous four years excludes the discount (Income Tax Law supplementary Art. 121).

Can we correct some invoices and defend others?

Yes. The company should explain in writing the documented criterion that separates corrected from defended invoices, so that the partial correction is not read as knowledge of the problem.

What if an examination has already started?

Voluntary disclosure is closed and the 50% penalty rule for late returns no longer applies; the assessment follows the examination report. The focus shifts to the defence file, the examination records and, if the deduction is denied, the tax court action.

What happens if we do not reply to the letter?

TPL Art. 148 imposes a duty to provide information, and a special irregularity penalty can follow a written warning (TPL supplementary Art. 355). Silence is not a defence and leaves the risk analysis without the company’s evidence.

Related guides

• Fake Invoice Allegations and KURGAN Tax Audits in Turkey — the entry point to this series
• VAT Deduction Denied for Fake Invoices in Turkey: How the Assessment Is Calculated
• Personal Liability of Directors and Managers in Turkish Fake Invoice Cases
• Called to Give a Statement in a Turkish Fake Invoice Investigation
• Taxation of Foreign Institutional Investors in Turkey
• Legal Guide for Foreign Investors in Turkey (Türkiye) 2026
• Replying to KURGAN and Examination Preparation Letters (in Turkish)
• Knowing or Unknowing Use of Fake Documents: Intent Criteria (in Turkish)
• VAT Refund Suspended Because of Fake Documents (in Turkish)
• Reporting Fake Invoices and Criminal Complaints (in Turkish)
• Effective Repentance in Turkish Fake Invoice Cases
• Challenging a Fake Invoice Assessment in the Turkish Tax Court
• Fake Invoice and KURGAN Decision Tool (in Turkish)
• Supplier Due Diligence Against Fake Invoice Risk in Turkey
• Travel Bans in Turkish Fake Invoice Investigations
• Precautionary Attachment in Turkish Fake Invoice Cases
• Limitation Periods in Turkish Fake Invoice Cases