Tax Residency Certificate for Treaty Relief in Turkey

A tax residency certificate (in Turkish, mukimlik belgesi) is the document that lets a double taxation agreement (DTA) be applied to a payment. Without it, a Turkish company paying a dividend, interest or royalty to a foreign recipient has to withhold tax at the Turkish domestic rate, even if a treaty would allow less.

The rule is short, but it is often applied badly in practice: the certificate arrives after the payment, it covers the wrong year, the translation is not certified, or nobody checks whether the treaty actually gives a lower rate. This guide explains what the Revenue Administration (Gelir İdaresi Başkanlığı, GİB) asks for, what the certificate does not prove, and how a Turkish company obtains its own certificate when it earns income abroad.

Residence Certificates at a Glance

• Legal basis: GİB’s Double Taxation Agreements Circular No. ÇVÖA/2013-1 (20 December 2013) on residence certificates. Residence itself is defined in Article 4 of each treaty.
• Foreign recipient of Turkish income: a certificate from the competent authority of its own country stating that it is fully taxable there, plus a Turkish translation certified by a notary or by the Turkish consulate in that country.
• Who receives it: the Turkish payer, when the payer withholds the tax, or otherwise the relevant tax office. The payer keeps it and shows it to the authorities when asked.
• No certificate: the circular says Turkish domestic law applies instead of the treaty.
• Turkish company earning income abroad: it requests a Turkish certificate from the office named in the circular, on paper or through the Interactive Tax Office.

Where the Rule Comes From

A treaty only protects residents of the two contracting states. Circular ÇVÖA/2013-1 states this directly: anyone who wants to benefit from a Turkish treaty must obtain, from the competent authority of the country where they are resident, a residence certificate showing that they are a full taxpayer there. The circular replaced the earlier circular ÇVÖA/2007-1 from 6 January 2014.

GİB publishes the list of agreements in force with the dates from which each applies, and the Turkish texts of the agreements. The list we checked is dated 23 April 2025 on the document. Before applying any treaty, confirm on the current list that the agreement with the recipient’s country is in force and applies to the tax year of the payment. Some partner states have a revised agreement that replaced an older one, so the date matters.

For an overview of how Turkish treaties allocate taxing rights, see our guide to double taxation agreements in Turkey.

Certificate From Abroad: What the Turkish Payer Needs

What the certificate should show

The certificate is issued by the tax authority of the recipient’s country, not by a commercial registry, bank or notary. A certificate of incorporation, a VAT registration or a good-standing letter does not prove tax residence.

Before accepting it, the Turkish payer should check that the certificate:

• names the same legal person that appears on the contract, invoice, share ledger and bank account;
• is issued by the competent authority of the treaty partner;
• states that the person is resident, or fully taxable, in that country; and
• covers the period in which the payment is made.

Differences in name caused by a merger, a change of trade name or a branch should be resolved before payment, not after.

Original plus a certified Turkish translation

The circular asks for the original certificate and a copy of its Turkish translation certified either by a notary or by the Turkish consulate in the issuing country. Both are given to the Turkish payer when the payer withholds the tax on the payment. Where no withholding agent is involved, they go to the relevant tax office.

The payer keeps the documents so that it can present them to the authorities when needed. In practice this means the certificate sits in the withholding file for the payment, together with the contract, the invoice or resolution, and the calculation.

Apostille and validity: what the circular does not say

The circular does not mention an apostille, and it does not set a fixed validity period. Two practical points follow.

First, do not tell the foreign recipient that an apostille is always required, but do ask the notary who will certify the translation, or the tax office, whether they need any authentication of the foreign document before they work with it.

Second, because the treaty applies to residents of the partner state, the certificate should cover the year in which the income is paid. Many authorities issue certificates for a calendar or tax year. A certificate for an earlier year does not show residence today, so ask for a new one when the payment falls into a new period.

No Certificate, No Treaty Rate

The circular is explicit: if the residence certificate cannot be presented, Turkish domestic law applies instead of the treaty. For a dividend paid by a Turkish company to a foreign company, that currently means withholding at 15% under Corporate Tax Law (KVK) Article 30(3), as set by Presidential Decision No. 9286 for dividend payments from 22 December 2024. See our dividend repatriation guide for the full distribution process.

The timing problem is real. Withholding applies when the amount is paid or credited to the recipient’s account, so the certificate has to be on file by then. If it arrives later, the tax has usually already been withheld at the domestic rate. Recovering the difference is a separate claim with the tax office, it is not automatic, and its route and time limit should be confirmed before anyone books the refund as certain.

The safest approach is simple: ask for the certificate when the contract is signed or the dividend is planned, not when the transfer order is ready.

A Certificate Is Not the Whole Treaty Test

A residence certificate proves one condition. A reduced rate usually depends on several more, and the Turkish payer is the one that applies the rate.

Beneficial ownership

Many Turkish treaties limit source-state tax only if the recipient is the beneficial owner of the income (Turkish texts use the term gerçek lehdar). For example, Article 10 of the Turkey–United Kingdom agreement limits Turkish tax on dividends only where the beneficial owner of the dividends is a UK resident. A company that receives the income only to pass it on may hold a valid certificate and still fail this test.

The right article and its conditions

Dividends, interest, royalties and business profits are dealt with in different articles. Each has its own definitions and, for dividends, often a shareholding threshold. The payer should identify the article first, then check the conditions in the actual treaty text and any protocol.

Whether the treaty improves on domestic law

A treaty limits Turkey’s tax; it does not raise it. If the treaty ceiling is higher than the domestic rate, the domestic rate applies and the treaty brings no saving. GİB’s own dividend table shows, for example, that the UK agreement allows Turkey 15% for a company controlling at least 25% of the voting power and 20% in other cases. Against the current 15% domestic dividend rate, a UK parent gains nothing from the treaty on dividends.

A Turkish permanent establishment

If the foreign company earns the income through a permanent establishment in Turkey, the treaty usually treats it as business profit of that establishment rather than under the dividend, interest or royalty article. Our permanent establishment guide explains when a foreign company’s activity creates one.

A Turkish Company That Needs Its Own Certificate

The same circular covers the opposite direction: a Turkish company, including a foreign-owned subsidiary, that earns income in a treaty country and needs to prove Turkish residence there.

Who issues it

Under the 2013 circular, certificates for Turkish full taxpayers are issued by:

• the Large Taxpayers Office (Büyük Mükellefler Vergi Dairesi Başkanlığı), for its own taxpayers;
• the tax office directorates in Ankara, Antalya, Bursa, İstanbul, İzmir, Kocaeli and Trabzon, for permanent taxpayers registered with the tax offices under them; and
• GİB’s European Union and Foreign Relations Department, for foreign national individuals, for certificates to be given to the Austrian, Swiss or Saudi authorities, and for anyone not covered above.

A company applies with the petition set out in the circular’s annex for legal persons. The circular also has special forms for certificates to be given to the authorities of Azerbaijan and Greece.

The online request

GİB’s Interactive Tax Office (İnteraktif Vergi Dairesi) user guide describes a residence-certificate request petition. In it the company enters the type of foreign income, the country it comes from, the years concerned, the foreign payer’s name and address, and the gross amount and currency. The guide says the certificate is sent by registered post, and a foreign address can be given. The request is then tracked under the company’s submitted petitions.

What the foreign country requires

Whether the foreign payer needs the Turkish certificate, a local form or both, and when it must be provided, is a matter for that country’s rules. Ask an adviser in that country before the first invoice; we do not set out foreign procedures here.

Practical Checklist for the Turkish Payer

1. Identify the recipient, the income type and the treaty article before the payment date.
2. Confirm on GİB’s list that the agreement is in force for the year of payment.
3. Compare the treaty ceiling with the current domestic rate; stop if the treaty brings no reduction.
4. Ask for the residence certificate for the year of payment, and arrange the certified Turkish translation.
5. Document beneficial ownership and any shareholding condition.
6. Withhold at the lower lawful rate, report it on the withholding return and keep the file.
7. If the certificate arrives late, withhold at the domestic rate and assess a refund claim separately.

Our corporate tax guide covers the company-level tax that sits underneath these withholdings, and our company registration practice explains how we set up the company and its tax registration in the first place.

Official Sources

• GİB: Circular ÇVÖA/2013-1 on residence certificates
• GİB: List of double taxation agreements in force
• GİB: Treaty rates on dividends in the source state
• GİB: Turkey–United Kingdom agreement, Turkish text
• GİB: Corporate Tax Law, Article 30
• GİB: Interactive Tax Office user guide

Plan the Treaty File Before the Payment

Treaty problems are often timing problems: the money moves first and the paperwork follows. Celikel CPA can check whether a treaty actually reduces the Turkish rate, prepare the withholding file, handle the Turkish translation route and file the withholding return. Official filings and correspondence with Turkish authorities are made in Turkish; we work with clients in English, Turkish, Russian, Chinese and Arabic. Talk to our tax services team before the next dividend, royalty or interest payment.