Companies in Turkey must keep and certify their commercial ledgers digitally under Tax Procedure Law No. 213 and the Turkish Commercial Code, with strict penalties for late or missing opening and closing certificates. Non-compliance can lead to heavy fines, denied VAT deductions, blocked refunds, loss of evidential value in court, and even prison, making e-Ledger management a critical compliance priority.
E-Ledger Compliance in Turkey
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Turkey
Author: Ivana Picajkić
Category:
Fiscal subject related
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Content accuracy validation date:
11.09.2025
Content accuracy validation time:
08:06h
Companies in Turkey must keep their commercial ledgers digitally under the Tax Procedure Law No. 213 and the Turkish Commercial Code (TCC). Each ledger is validated with a digital certificate that proves the content has not been changed and was submitted on time.
- Opening certificate: For the first month of the accounting period (like notary approval for paper books),
- Closing certificate: For the last month of the period. Missing these deadlines is considered a serious violation and leads to strict penalties.
Late or missing certificates bring direct fines:
- Special irregularity penalties,
- If the opening certificate is more than one month late, the book is treated as “never certified,” and further fines apply,
- Missing the closing certificate also triggers fines under both Tax Law No. 213 and TCC,
- Not submitting ledgers in audits may be treated as hiding records (VUK 359), with risk of prison.
Beyond fines, non-compliance causes bigger problems:
- VAT deductions can be denied if records are uncertified,
- Tax base may be set by the tax office directly (ex officio assessment),
- Books may lose evidential value in court,
- VAT refunds can be suspended, affecting cash flow.
Events like cyberattacks, system failures, or natural disasters may excuse delays if proven. Taxpayers must apply to court within 15 days to get a loss certificate, otherwise the defense may fail.
Within 30 days of a penalty notice, taxpayers may:
- Reconcile with the tax office,
- Request a reduction (VUK 376),
- File a lawsuit to cancel the penalty; this pauses collection until judgment.
Common arguments include:
- Force majeure: Proving unforeseeable events (illness, disaster, cyberattack),
- Notification errors: If e-notifications were sent incorrectly or not accessible,
- Statute of limitations: Fines cannot be imposed after five years,
- Proportionality: Penalties must match the seriousness of the violation; excessive fines may be unconstitutional.
Non-compliance with e-Ledger rules can lead to heavy fines, denied VAT deductions, blocked refunds, and even prison. Companies must treat e-Ledger management as a priority, ensure IT and accounting teams coordinate, prepare for risks like cyberattacks, and act quickly with advisors if penalties arise.
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