On June 6, 2026, the Turkish Official Gazette published Presidential Decision No. 11396, confirming the ratification of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. The agreement, formally signed by the Republic of Turkey in Ankara on April 20, 2026, establishes the legal and operational framework for the automatic exchange of tax data concerning large multinational enterprises.
This development is a direct implementation of the Global anti-Base Erosion (GloBE) Rules developed by the OECD/G20 Inclusive Framework. The primary objective of these rules is to ensure that certain large Multinational Enterprise (MNE) Groups pay a minimum level of tax on the income arising in each jurisdiction where they operate.
For foreign investors, multinational corporations, and tax compliance teams operating within Turkey, this agreement dictates how the Turkish Revenue Administration will receive, process, and share corporate tax data with foreign jurisdictions.
The Structure of the GloBE Information Return
To support the administration of the GloBE Rules, constituent entities located in implementing jurisdictions are required to file a GloBE Information Return with their local tax administration.
This return is highly structured and consists of two primary components:
- The General Section: This section provides general information regarding the MNE Group as a whole. It includes the corporate structure of the enterprise and a high-level summary of the relevant GloBE information.
- The Jurisdictional Sections: These sections contain detailed information reflecting the specific application of the GloBE Rules for each jurisdiction where the MNE Group operates. Where applicable, it also includes data on the Qualified Domestic Minimum Top-up Tax (QDMTT).
Centralized Filing and Exemption from Local Filing Requirements
A key compliance mechanism within the GloBE Rules is the centralization of reporting to reduce the administrative burden on MNEs. The rules discharge a constituent entity from the requirement to file a GloBE Information Return directly with the local tax administration if a specific condition is met.
The local entity is exempt if the return is filed by the filing deadline by the Ultimate Parent Entity or a Designated Filing Entity. This filing must take place in a jurisdiction that has established a Qualifying Competent Authority Agreement with the local implementing jurisdiction.
Because the agreement published in the Official Gazette functions as a Qualifying Competent Authority Agreement, Turkish subsidiaries of foreign MNEs can rely on centralized filings submitted by their parent entities abroad, provided an active exchange relationship exists with the respective foreign tax authority.
The Dissemination Approach: How Tax Data is Shared
The transmission of the GloBE Information Return between tax authorities is governed by a multilaterally agreed framework known as the Dissemination Approach. This approach determines exactly which sections of the return are provided to each jurisdiction based on the MNE Group's corporate structure and the rule order under the GloBE Rules.
Under the Dissemination Approach, the information is distributed as follows:
- The General Section is provided to implementing jurisdictions where the Ultimate Parent Entity or constituent entities of the MNE Group are located.
- The General Section (excluding the high-level summary of GloBE information) is provided to QDMTT-only jurisdictions where constituent entities, joint ventures, or stateless constituent entities of the MNE Group are located.
- One or more Jurisdictional Sections are provided to the specific jurisdictions that hold taxing rights under the GloBE Rules or the QDMTT in respect to the jurisdictions those sections relate to.
- The implementing jurisdiction where the Ultimate Parent Entity is located receives all Jurisdictional Sections.
Deadlines and Technical Mechanisms for Information Exchange
The agreement establishes strict timelines for the competent authorities to exchange the received tax data. Based on the designations of the Ultimate Parent Entity or Designated Filing Entity, competent authorities will exchange the information automatically.
- Standard Deadline: Information included within a GloBE Information Return must be exchanged no later than three months after the filing deadline in the sending jurisdiction for the relevant Reporting Fiscal Year.
- First Reporting Fiscal Year: For the first reporting year specified by the competent authority, the exchange deadline is extended to no later than six months after the filing deadline in the sending jurisdiction.
- Late Filings: If a competent authority receives a GloBE Information Return after the local filing deadline, it must exchange that information within three months following the date of receipt.
To ensure technical uniformity, the authorities will automatically exchange the information using a common schema written in Extensible Markup Language (XML). The transmission of this data will be executed through the OECD Common Transmission System, strictly complying with related encryption and file preparation standards.
Confidentiality and Data Safeguards
The handling of sensitive corporate tax data is strictly regulated. All information exchanged under this agreement is subject to the confidentiality rules and other safeguards provided for in the Convention on Mutual Administrative Assistance in Tax Matters. This includes explicit provisions that limit the use of the exchanged information.
If a breach of confidentiality or a failure of data safeguards occurs, the competent authority must immediately notify the OECD Co-ordinating Body Secretariat. The Secretariat will then notify all other competent authorities that hold an active agreement with the authority reporting the breach.
Procedures for Corrections and Compliance Inquiries
The agreement outlines formal procedures for situations where the exchanged information is incomplete, incorrect, or delayed.
If a competent authority has reason to believe that the information contained within a GloBE Information Return requires correction, it may notify the competent authority of the jurisdiction where the Ultimate Parent Entity or Designated Filing Entity is located. If the notified authority agrees that corrections are necessary, it must take appropriate measures to obtain the corrected information from the reporting entity without undue delay. Once obtained, the corrected information must be exchanged immediately with all relevant competent authorities.
Additionally, a local tax administration may receive notification from a local constituent entity stating that the GloBE Information Return was filed abroad. If the local tax administration does not receive the relevant data from the foreign authority within the specified three-month or six-month deadline, it may issue a notification to that foreign authority. The foreign authority is then required to determine the reason for the delay and inform the notifying authority within one month of receiving the notification.
Turkey's Diplomatic Reservation
Foreign investors must take note of a specific legal reservation attached to Turkey's ratification of the agreement. Through a formal declaration signed by the Deputy Commissioner of the Turkish Revenue Administration, the Republic of Turkey stated that it will implement the provisions of the Convention and the Protocol exclusively with respect to State Parties with which it maintains diplomatic relations. MNEs headquartered or operating in jurisdictions lacking formal diplomatic ties with Turkey must evaluate alternative compliance strategies, as the automatic exchange mechanisms and local filing exemptions may not apply.
Frequently Asked Questions (FAQs)
What is the core purpose of the Multilateral Competent Authority Agreement on GloBE Information?
The agreement facilitates the automatic exchange of information contained within GloBE Information Returns among participating tax authorities. Its objective is to ensure that certain large Multinational Enterprise Groups pay a minimum level of tax on income generated in every jurisdiction where they conduct operations.
Do Turkish constituent entities of a foreign MNE need to file a GloBE Information Return locally?
Under the GloBE Rules, a local constituent entity is discharged from the requirement to file the return directly with the local tax administration if the return is filed on time by the Ultimate Parent Entity or Designated Filing Entity in a jurisdiction that has an active Qualifying Competent Authority Agreement with the local jurisdiction.
What specific information is included in the General Section of the GloBE Information Return?
The General Section contains general information about the MNE Group as a whole. This includes the corporate structure of the enterprise and a high-level summary of GloBE information.
How quickly must tax authorities exchange the GloBE Information Returns?
Competent authorities must exchange the information no later than three months after the filing deadline in the sending jurisdiction. However, for the first Reporting Fiscal Year, the authorities are granted an extended deadline of up to six months after the filing deadline.
What technical standards govern the data transmission?
Information is exchanged automatically using a common schema in Extensible Markup Language (XML). The data is transmitted securely through the OECD Common Transmission System in compliance with strict encryption and file preparation standards.
What procedure is followed if a tax authority believes the received information is incorrect?
The authority identifying the issue may notify the competent authority of the jurisdiction where the filing entity is located. If both authorities agree that a correction is required, the notified authority must secure the corrected information from the filing entity and exchange it with all relevant authorities without undue delay.
Will Turkey exchange GloBE information with every signatory jurisdiction?
No. In an official declaration attached to the agreement, the Republic of Turkey explicitly stated that it will implement the provisions of the Convention and the Protocol only with respect to State Parties with which it has diplomatic relations.
