Fiscal subject related
The Ministry of Treasury and Finance has announced a new tax audit policy that will take effect on October 1, 2025, marking a major shift in the fight against fake and misleading documents (SMİYB). The policy relies on artificial intelligence and advanced risk analysis tools of the Tax Inspection Board (VDK) to quickly detect suspicious transactions.
The policy introduces a tougher approach where the defense of “unknowing use” will no longer be accepted. From this date, all detected cases will be presumed intentional, exposing taxpayers to heavy administrative and criminal sanctions, including triple tax loss penalties and prison terms of 3–8 years under Article 359 of the Tax Procedure Law.
At the heart of the reform is the Tax Inspection Board’s AI-powered KURGAN system, which will automatically and rapidly detect fraudulent transaction chains. Unlike past audits that often focused on previous years, these systems will enable real-time detection and action. In addition, preventive measures will allow authorities to request financial guarantees at the start of an audit. If taxpayers cannot provide them, the administration may impose precautionary liens, potentially freezing commercial activity.
To adapt, taxpayers must shift from passive compliance to active risk management. This includes:
- Supplier and customer checks: verifying official records, confirming physical operations, checking financial reputation, and continuously monitoring existing suppliers, especially in high-risk sectors.
- Detailed transaction documentation: keeping full evidence for each stage of trade, from contracts and delivery notes to service reports and transparent bank payments. Invoices alone will no longer be sufficient.
- Stronger internal controls: applying segregation of duties, four-eye checks, periodic internal audits, and ensuring that tax returns fully match e-Ledger and e-Invoice records.
- Rapid response to tax authority letters: warnings about risky suppliers must be treated as red flags, with immediate corrections filed under VUK Articles 370 or 371 if needed.
For professionals such as CPAs and YMMs, responsibilities will expand significantly. They are expected to educate clients about the new regime, design stronger internal control systems, advise on supplier risk assessments, and adopt a more skeptical stance when reviewing documentation.
The government stresses that this new regime is not just an administrative change but a complete restructuring of tax compliance. Businesses that fail to adapt face not only severe financial losses and rejected VAT deductions, but also criminal liability. For companies, proving the authenticity of every transaction will be essential to sustaining operations under the new rules.
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