EXTENSION OF THE SUBMISSION DEADLINE FOR SPECIAL-PURPOSE SWORN-IN CERTIFIED PUBLIC ACCOUNTANT (YMM) REPORTS RELATING TO NON-DEDUCTIBLE VAT UNDER PRESIDENTIAL DECISION NO. 7846
Presidential Decision No. 7846, which entered into force on 24 November 2023, disallows the deduction of VAT arising from three specific categories of import transactions: amounts declared on customs declarations in relation to goods subject to import surveillance that cannot be substantiated, customs duties and/or additional financial obligations applied as safeguard measures, and anti-dumping duties and countervailing duties. VAT calculated on amounts falling into any of these three categories, and included in the VAT base as a result, may no longer be deducted.
This regulation applies only to taxpayers carrying out import transactions falling within the three categories described above. A standard import transaction that is not subject to surveillance, safeguard measures, or anti-dumping/countervailing duties — regardless of its value — falls entirely outside the scope of this regulation and gives rise to no notification or reporting obligation. The TRY 2,600,000 threshold discussed below is likewise assessed not against a taxpayer's total import volume, but solely against the portion of imports falling within these three categories during the relevant six-month period.
Although the restriction itself has been in force since 2023, no concrete mechanism existed until recently for verifying taxpayers' compliance with it in practice. This gap was closed by General Communiqué on Value Added Tax (Serial No. 57), which entered into force on 31 January 2026 and introduced a new section (III/C-2.6.2) to the General Communiqué on VAT Implementation. Under this provision, taxpayers with imports falling within the scope of Decision No. 7846 must substantiate, for each six-month period of the calendar year, that the relevant VAT has been correctly excluded from deduction, through one of the following two methods:
- Where the value of imports falling within the scope of the Decision does not exceed TRY 2,600,000 (the threshold set out in Article 3 of General Communiqué No. 46 on Independent Accountancy, Financial Advisory and Sworn-in Certified Public Accountancy Law) for the relevant six-month period, it is sufficient to notify the taxpayer's affiliated tax office by the end of the month following that period.
- Where this amount is exceeded, taxpayers who do not hold a full certification (tam tasdik) agreement for the year in which the import took place must submit a special-purpose report prepared by a Sworn-in Certified Public Accountant (Yeminli Mali Müşavir, "YMM") addressing this specific matter, by the end of the month following the six-month period. Where a full certification agreement duly executed for that year is in place, and the resulting full certification report includes an explanation as to whether the relevant VAT has been correctly excluded from deduction, no separate YMM report is required.
As the regulation entered into force on 31 January 2026, its first applicable period is January–June 2026, for which the notification/reporting deadline would ordinarily have expired on 31 July 2026.
Extension of the Deadline
Under Value Added Tax Circular No. 71, issued by the Revenue Administration on 27 July 2026, and pursuant to the repeated Article 227 of Tax Procedure Law No. 213, the submission deadline for special-purpose YMM reports applicable to taxpayers whose imports falling within the scope of Decision No. 7846 exceeded TRY 2,600,000 during the first half of 2026 (January–June) has been extended to 31 August 2026. This extension applies solely to the special-purpose YMM report obligation and does not address the notification obligation applicable to transactions below the TRY 2,600,000 threshold.
Our Observations
In this context:
- The first step is to determine whether your company carried out any imports subject to import surveillance, safeguard measures, or anti-dumping/countervailing duties during the first half of 2026 — if none of these three situations apply, the remaining steps below are not relevant to your company.
- Where such imports exist, it should be determined whether their total value for the relevant six-month period exceeds the TRY 2,600,000 threshold.
- If the threshold is exceeded and no full certification agreement is in place for 2026, a special-purpose YMM report must be submitted by 31 August 2026.
- If a full certification agreement is in place, it should be confirmed with your Sworn-in Certified Public Accountant that the full certification report includes the required explanation on this matter.
