VAT Requirements for Non-Resident Electronic Service Providers in Turkey - Comprehensive Guide 2026 

In Turkey, non-resident companies providing electronic services to Turkish consumers are legally required to register for VAT even if they do not have a permanent establishment in Turkey. They must do so through the “Special VAT Liability for Electronic Service Providers” framework.

This registration is done in the name of the non-resident company, typically via the Large Taxpayers Office, and requires submitting the 3rd-type VAT return electronically.

VAT Requirements for Non-Resident Electronic Service Providers in Turkey

On the 1 January 2018, the VAT rules for sales of electronic services to non-VAT registered individuals by electronic service providers who do not have a residence, business place, legal business centre and business centre in Turkey have changed.

Non-resident electronic service providers have to declare and pay VAT which is charged on electronic services to non-VAT registered individuals. This change is only applicable to B2C transactions and irrelevant for B2B sales, where a reverse charge mechanism is still applicable. For cross border supplies of electronic services there is no registration threshold and therefore registration obligation arises as of the first revenue.

According to the first paragraph of duplicate Article 257 of the Law No. 213; Ministry of Finance has the authority to designate the basis of filing declarations and notifications in any kind of electronic data transmission tools and environment including the Internet by using password, electronic signature and other security tools, to designate the procedure and basis for format, standard and implementation that will be followed in their transmission, to implement or designate these obligations and standards separately for taxpayer groups and fields of activity, and to send online notifications of tax assessment notices created upon declarations and/or notifications.

Special VAT Liability for Electronic Service Providers: How to manage 3rd type VAT returns for non-resident companies

Those who provide services in electronic environment for remuneration to real persons who have no VAT liability, without having residence, business place, legal center and business center in Turkey declare the VAT related to these services by registering for "Special VAT Registration for Electronic Service Providers".

Such service providers declare the VAT related to these transactions electronically with the VAT Declaration No. 3.

The service providers in this scope must fill in the form on Turkish Revenue Administration's website  before filing the VAT Declaration No.3 for the first time.

Upon completing and filing the aforesaid form in electronic environment, "Special VAT Registration for Electronic Service Providers" will be registered in the name of the service provider at Large Taxpayers Tax Office Directorate.

These taxpayers are not required to file the start of business notification. After the registration of liability, taxpayers are assigned user code, password and code for making transactions on Internet tax office.

Those who register for Special VAT Registration for Electronic Service Providers are not required to have their declarations signed by a professional intermediary as it is set in the duplicate Article 227 of the Law No. 213 without any limitation.

Typical process and timeline for VAT registration

For non-resident companies providing electronic services to Turkey, the typical VAT registration process is as follows:

1.      Preparation (3–5 days): Gather required documents, including corporate registration, authorized signatory info, and proof of identity. For U.S. companies, documents must be notarized and apostilled.

2.      Submission to Turkish Tax Office (1–2 days): Registration is submitted electronically via the Internet Digital Tax Office

3.      Tax Office Review (1 week): Authorities review submitted documents and verify the appointed tax agent or fiscal representative.

4.      VAT Number Issuance (2 weeks total): Upon approval, a special VAT number for non-resident electronic service providers is issued.

5.      Ongoing Filing: Once registered, monthly VAT returns must be submitted by the 24th of the following month using the 3rd-type VAT return.

Overall, the end-to-end registration process typically takes 2 weeks max., assuming documents are complete and correctly submitted.

Typical process and timeline for each VAT filing for Non-Resident Electronic Service Providers in Turkey

Typical VAT filing process for non-resident electronic service providers in Turkey:

1.      Data Validation & Draft Preparation (6–13th): Client shares transaction data for the previous month in a standardized format (CSV, Excel, or API export). The service provider reviews data, calculates VAT, and prepares a draft 3rd-type VAT return. Any inconsistencies are flagged for client clarification.

2.      Draft Review & Approval (14–20th): Draft return is shared with client via secure portal or encrypted email. Client confirms accuracy and authorizes submission.

3.      Submission (20–24th): VAT return is filed electronically through the Internet Digital Tax Office. The deadline is 24th of each month. Taxpayers who are not resident in Turkey and have Special VAT Tax liability shall declare the VAT calculated for the services they provide online to individuals who are resident in Turkey and are not VAT taxpayers, as of the monthly taxation periods of the calendar year, in Turkish Lira, via the online tax office and with VAT Declaration No. 3, by the evening of the 24th day of the month following the taxation period.

4.      Payment: ( 24-26 th): The taxpayers who are in the scope of Special VAT Registration for Electronic Service Providers declare the VAT related to serviced they provide to non-VAT taxpayers in Turkey in electronic environment until the night of the 24th day of the month following the taxation term as per monthly taxation terms of the calendar year. The VAT declared in this context must be paid until the 26th night of the month that the declaration must be filed in. According Regulation of Revenue Administration on tax collections to be made through banks as of 01.01.2020, the tax payment of VAT Return for e-service providers can make

·        on the web page using DEBIT cards (Turkish public bank or all foreign banks ) and

·        only foreign bank credit cards or

·        EFT to the bank account of The Large Taxpayer Tax Office.

5.      Record Storage & Reporting: Filed returns and supporting documents are stored securely for at least 10 years, per Turkish tax law. Audit-ready reports are made available to the client.

Tax Remittance workflow and options when client lacks local bank account

According Regulation of Revenue Administration on tax collections to be made through banks as of 01.01.2020, the tax payment of VAT Return for e-service providers can be done on the web page using

1. DEBIT cards (Turkish public bank or all foreign banks ) and ( Minor processing fees  may apply)
2. only foreign bank credit cards ( Minor processing fees  may apply)
3.  or EFT/Swift to the bank account of The Large Taxpayer Tax Office. ( in Turkish Liras)

Hence; the client may pay the amount due easily from abroad.

If this is not preferred, we can also handle the payment locally using our resources; once we receive from the client the amount in our bank accounts: We remit VAT on behalf of the client using our account and provide a full payment confirmation. (This is subject to extra small service fees)

All payments are documented and reconciled against filed returns. Clients receive a copy of the official receipt and full reconciliation for audit purposes.

Are non-resident companies legally required to appoint a tax agent and/or fiscal representative to register and file for VAT?

Quoting official documents "Those who register for Special VAT Registration for Electronic Service Providers are not required to have their declarations signed by a professional intermediary as it is set in the duplicate Article 227 of the Law No. 213 without any limitation.", as you may see there is no mandate in appointing any kind of tax agent / fiscal representative or CPA for the VAT Compliance in Turkey.

While a formal fiscal representative or tax agent is not mandatory under this scheme, non-resident companies are required to appoint an Authorized Contact Person ( not an authorized signatory) to complete the registration form on the GİB digital service portal.

The main duty of The Authorized Contact Person  is to receive any messages/declaration/warnings/from the Large Taxpayers Office  about VAT declaration/return and payment and vice versa. So mainly it's the main contact to talk with in the first place. However, except the transmissions of the messages and/or meeting results; there is no official obligation.

In practice, many non-resident service providers appoint an Authorized Contact Person (a local tax advisor or accounting firm) to manage compliance, given the language, procedural, and reporting requirements. This ensures correct VAT reporting, timely payment, and adherence to Turkish tax law without establishing a physical presence.

If the service provider is acting as the tax agent or fiscal representative for a non-resident comapnies filing for VAT, do the service provider need to have any certification?

No specific legal certification is required for a service provider acting as the tax agent or managing VAT filings on behalf of non-resident companies in Turkey. The law does not mandate that the representative be a certified accountant, lawyer, or licensed tax advisor. ( The law doesn't mandate a so called "representative" at all)

However, in practice, most non-resident companies engage qualified tax professionals or accounting firms with experience in VAT compliance for foreign entities. This is because the process involves

·        electronic registration with the Large Taxpayers Office,

·        submission of 3rd-type VAT returns,

·        accurate calculation of VAT on electronic services,

·        and proper record-keeping according to Turkish tax regulations.

The representative essentially acts as the operational arm for VAT reporting but does not need a formal government-issued certification.

As CPATurk, we possess all the necessary certification to do Tax, Audit and Advisory Services in Turkey.

VAT Registration document list required for foreign entities with no permanent establishment locally

For foreign companies with no permanent establishment in Turkey, VAT registration as a non-resident electronic service provider generally requires the following documents:

1.      The National VAT Registration Number or Tax Registration Number

2.      The National Trade Registration Number

3.      Full Name of The Company

4.      The Trading Name of The Company

5.      The Full Postal Address of Company in the Country of Residence or Place of Business

6.      Country of Residence or Place of Business Of Company

7.      The E-Mail Address of Company

8.      The Website of Company

9.      Name and Surname of Authorized Contact Person of Company

10.   Postal Address of Authorized Contact Person

11.   The E-Mail Address of Authorized Contact Person

12.   Telephone Number of Authorized Contact Person

13.   Type of Electronic Services Supplied by Company    

14.   Website Address Where Electronic Services are Supplied by Company  

15.   Mobile Applications Where Electronic Services are Supplied by Company 

16.   Information About The Bank Account International Bank Account Number (IBAN)

17.   Completed VAT Registration Form – Submitted electronically via the Digital Services Portal.

In order to be able to prove legally above mentioned information, following documents should be sent to CPATurk for verification purposes:

1.      Company Extract / Certificate of Incorporation – Issued by the state of incorporation, showing legal existence and authorized signatories.

2.      Tax Identification Number or Equivalent – From the home country for verification purposes.

3.      Board Resolution or Power of Attorney – Authorizing a representative / Authorized Contact Person  (tax agent or accounting firm) to act on behalf of the company in Turkey.

4.      Authorized Signatory Identification – Passport or official ID of the person submitting registration. ( If this person is appointed inhouse)

These documents are typically submitted in English, sometimes requiring notarization or apostille, and processed by the Large Taxpayers Office to establish the “Special VAT registration” for electronic service providers.

Is there any other obligation than filing VAT Returns for non-resident companies selling services to Turkish customers? If yes, what are the obligations?

Yes, there is one more obligation if you are selling also B2B in Turkey.

In other words, if you sell also to businesses (beside selling to individiuals), you have one more obligation:  As is well known from 1 January 2018, VAT rules for sales of electronic services for consideration to non-VAT registered individuals by electronic service providers who do not have residence, business place, legal business center and business center in Turkey changed. Non-resident electronic service providers have to declare and pay VAT which is charged on electronic services to non-VAT registered individuals.

            The regulation doesn’t affect business to business sale, the reverse charge mechanism will continue to be implemented.

B2B Sales List Declaration Return

            However, from 1 January 2019, taxpayers who registered as “Special VAT Registration for Electronic Service Providers” should declare their sales of electronic services to businesses (B2B). Declaration should be prepared as a list and uploaded to the system.

I - PREPARING LIST:

             You must prepare the lists that contain the following information in xml format. You can use the .xsd file for the XML structure. The size of one XML file must be up to 10 megabytes. Multiple files can be loaded if needed.

·        Purchaser-Tax Registration Number

·        Purchaser- Name and Surname/Trade name (Mandatory)           

·        Purchaser- Address         

·        Currency of Payment (Mandatory)    

·        Price of Service (Mandatory)          

·        Payment Method (Mandatory)   

·        Issued Invoice- Date (Mandatory)          

·        Issued Invoice-Number (Mandatory)

II - LOAD LISTS:

             The lists must be submitted in the same period as the VAT return period as a different return/declaration. This operation does not cause any tax payment for the client. It's only declaration-obligation.

End-to-End VAT Registration & Filing for Non-Resident Clients

Here is a description in detail about the process and the support provided for managing standard VAT registration and filling cases, end-to-end.

1.      Onboarding & Docs: Collect company certificate, articles of association, tax residence certificate, proof of commercial activity, authorized signatory info.

2.      VAT Registration: Submit via İnternet Vergi Dairesi (GİB portal). Assign a Authorized Contact Person (aka local tax agent). VAT number issued.

3.      Data Collection: Clients provide transaction data in CSV/Excel/XML. Validate sales, VAT rates, reverse charge rules, 3rd-type VAT application.

4.      Draft & Approval: Prepare draft return on GİB portal. Highlight input/output VAT, reverse charge. Client reviews the draft and approves.

5.      Submission & Payment: Submit electronically. Facilitate payment if client lacks local bank account. Ensure accurate 3rd-type VAT reporting for digital services.

6.      Reporting & Record-Keeping: Store filings and receipts securely. Audit-ready.

7.      Ongoing Support: Monitor regulatory updates, handle corrections, advisory on Turkish VAT compliance.

Our firm provides centralized VAT services through a structured, end-to-end framework designed for non-resident clients. Key elements include:

1.      Dedicated client teams: Each client has a primary point of contact and a small specialized team overseeing registration, filings, compliance, and reporting.

2.      Scalable operational network: We retain ultimate responsibility while leveraging a network of highly skilled freelance CPAs and licensed accounting firms for high-volume or complex cases.

3.      Automated workflows: Standardized templates (CSV/Excel) and automated alerts streamline data collection, validation, and exception handling.

4.      Risk and control focus: Drawing on our audit and IT expertise, we implement controls to ensure accuracy, mitigate errors, and maintain compliance.

5.      Direct oversight: Our management reviews all filings and submissions, maintaining quality and accountability across all operations.

CPATURK’s unique strengths and advantages specific to the practice of tax: What value do we bring to our clients in the field?

Our firm’s unique strengths lie in combining audit-grade rigor, technology expertise, hands-on international SaaS experience, and scalable operational support—four dimensions that differentiate us from competitors:

1.      Audit perspective: Operating with the identity of an independent audit firm, we embed risk-reducing controls directly into operational VAT processes. This ensures compliance integrity while managing day-to-day filings.

2.      IT & cybersecurity expertise: Our dedicated IT audit team is highly skilled in information security, cyber risk, and emerging technologies, allowing us to navigate digital service compliance efficiently and securely.

3.      Hands-on SaaS & US experience: Our team has previously founded and managed SaaS companies in the U.S., selling to global customers through U.S.-based payment systems (e.g., Stripe) and maintaining accounting in QuickBooks. This gives us direct, practical understanding of the challenges Numeral’s clients face.

4.      Direct oversight with scalable operational support: We retain ultimate responsibility while leveraging a network of highly skilled freelance CPAs and licensed accounting firms for high-volume or complex cases, ensuring timely, reliable, and flexible VAT compliance.

COMMUNIQUÉ
ON AMENDING THE GENERAL VAT IMPLEMENTATION COMMUNIQUÉ
(SERIAL NO: 17)

ARTICLE 1 – In the General VAT Implementation Communiqué published in the Official Gazette dated 26/4/2014 and numbered 28983, within section (I/C), the heading “2.1.2.1. Transactions Carried Out by Those Whose Residence, Place of Business, Legal Head Office and Business Center Are Not Located in Türkiye” has been followed by the insertion of the heading “2.1.2.1.1. General”, and following this section, the section below has been added.

2.1.2.1.2. Services Supplied Electronically to Natural Persons Who Are Not VAT Taxpayers

With the amendment made to paragraph (1) of Article 9 of Law No. 3065 by Article 41 of Law No. 7061 dated 28/11/2017 on the Amendment of Certain Tax Laws and Certain Other Laws, it has been stipulated that the value added tax related to services supplied electronically to natural persons who are not VAT taxpayers by those whose residence, place of business, legal head office and business center are not located in Türkiye shall be declared and paid by the service providers themselves, and that the Ministry of Finance is authorized to determine the scope of electronically supplied services and the procedures and principles regarding their implementation.

Accordingly, services supplied electronically for consideration to natural persons who are not VAT taxpayers in Türkiye by persons whose residence, place of business, legal head office and business center are not located in Türkiye are subject to VAT, and the declaration and payment of VAT related to such services shall be subject to the procedures and principles set forth in this section.

In cases where electronically supplied services are provided in a manner constituting a place of business (whether a place of business is constituted in Türkiye shall be determined in accordance with the provisions of the Tax Procedure Law No. 213), the tax related to such services must be declared and paid within the framework of general principles (by submitting VAT Return No. 1).

2.1.2.1.2.1. VAT Liability of Electronic Service Providers

Under subparagraph (4) of the first paragraph of the repeated Article 257 of Law No. 213, the Ministry of Finance is authorized to require declarations and notifications to be submitted via all kinds of electronic information and communication tools and environments, including the internet, using passwords, electronic signatures or other security tools; to determine the formats and standards to be followed in their transmission and the procedures and principles regarding implementation; to apply or determine such obligations or standards separately by taxpayer groups and fields of activity; and to serve accrual slips and/or tax notices issued on declarations electronically.

Persons whose residence, place of business, legal head office and business center are not located in Türkiye and who supply services electronically for consideration to natural persons who are not VAT taxpayers in Türkiye shall declare the VAT related to such services by establishing a “Special VAT Liability for Electronic Service Providers.”

Such service providers shall declare the VAT related to these transactions electronically by submitting VAT Return No. 3.

Service providers within this scope must complete the form available at www.digitalservice.gib.gov.tr on the website of the Revenue Administration prior to submitting their first VAT Return No. 3.

Upon completion and electronic approval of the said form, a “Special VAT Liability for Electronic Service Providers” shall be established in the name of the service provider before the Large Taxpayers Tax Office Directorate.

No commencement of business notification shall be required from taxpayers within this scope. Upon establishment of the tax liability, the taxpayer shall be provided with a user code, password and PIN to conduct transactions through the internet tax office.

It has been deemed appropriate that those who establish a Special VAT Liability for Electronic Service Providers shall not be subject to the obligation to have their returns signed by certified professionals pursuant to repeated Article 227 of Law No. 213, without being subject to any threshold.

In cases where the electronic service provider is not explicitly specified, such situation is not reflected in the contract between the parties, and information regarding the service and the electronic service provider is not clearly stated on invoices and similar documents issued, the VAT related to electronically supplied services shall be declared and paid by intermediaries facilitating the electronic supply of services.

Moreover, those who have the authority to charge customers, determine the general terms of the service in question, or are obliged to perform the service shall be considered electronic service providers.

2.1.2.1.2.2. Calculation of the Tax

Those within the scope of the Special VAT Liability for Electronic Service Providers shall calculate VAT at the applicable rate for the services they supply electronically to natural persons who are not VAT taxpayers in Türkiye.

Persons subject to the Special VAT Liability for Electronic Service Providers are not required to keep books pursuant to Law No. 213.

Provided that they relate to services declared within the scope of the Special VAT Liability for Electronic Service Providers, the portion of VAT shown on invoices and similar documents issued for goods and services procured from VAT taxpayers in Türkiye that corresponds to the declared transactions may be deducted pursuant to Article 29(1) of Law No. 3065.

Such invoices and similar documents shall be retained in accordance with the record-keeping and submission provisions of Law No. 213.

2.1.2.1.2.3. Declaration and Payment

Those within the scope of the Special VAT Liability for Electronic Service Providers shall declare the VAT calculated due to services supplied electronically to natural persons who are not VAT taxpayers in Türkiye, in Turkish Lira, via the internet tax office and by submitting VAT Return No. 3, for monthly taxation periods of the calendar year, no later than the evening of the twenty-fourth day of the month following the taxation period.

However, it has been deemed appropriate that service providers whose residence, place of business, legal head office and business center are not located in Türkiye and who supply services electronically for consideration to natural persons who are not VAT taxpayers in Türkiye, shall declare transactions carried out during January, February and March 2018 by submitting VAT Return No. 3 no later than the evening of the twenty-fourth day starting from the beginning of April 2018, following the entry into force of the provision regarding the Special VAT Liability for Electronic Service Providers on 1/1/2018.

Taxpayers within this scope are not required to submit a return for the relevant period if there are no transactions requiring declaration.

If the consideration is calculated in foreign currency, the foreign currency shall be converted into Turkish Lira using the Central Bank of the Republic of Türkiye foreign exchange buying rate published in the Official Gazette on the date the taxable event occurs. For foreign currencies not announced by the Central Bank in the Official Gazette, the prevailing exchange rate shall be used.

VAT declared within this scope must be paid no later than the evening of the twenty-sixth day of the month in which the return is required to be filed.

Payment may be made to tax offices and authorized banks, as well as via the website of the Revenue Administration (www.gib.gov.tr) using bank or credit cards of authorized banks.

2.1.2.1.2.4. Failure to Fulfil Obligations

In cases of non-compliance with the provisions regarding the declaration obligation for electronically supplied services set forth in Article 9(1) of Law No. 3065, the provisions of Law No. 213 concerning tax penalties shall apply.