Electronic invoicing in Turkey
Complete overview of the electronic invoicing system in Turkey: current regulations, mandatory invoicing thresholds, UBL-TR formats used, centralized fiscal control process, and archiving and digital signature requirements.
Characteristics of Electronic Invoicing in Turkey
The Tax Procedure Law (VUK) of 2010 legally equated the electronic invoice (e-Fatura) to the paper invoice and entrusted its implementation to the Turkish Revenue Administration - TRA (Gelir İdare Başkanlığı, GİB). Roll-out has been staggered by sector and business volume:
- 2014: first large group of required parties.
- 2016: companies with revenue exceeding 10 million TRY.
- 2019: companies with revenue of over 5 million TRY.
- 2022 (July): threshold reduced to 4 million TRY (e‑Fatura and e‑Arşiv) and 10 million TRY for e‑İrsaliye.
- 2023 (July): taxpayers who invoiced over 3 million TRY in 2022 are added.
- 2023 (September): all e‑Fatura and e‑Arşiv must include a QR code.
In the B2G sphere, since March 2021, Turkish public bodies must accept electronic invoices, and their suppliers must issue them with the KAMU code if they are already registered with the TRA.
Mandatory Use
Currently, all companies that reach the annual tax threshold set by the TRA (3 million TRY for the 2022 fiscal year) or that belong to expressly regulated sectors (oil, alcohol, tobacco, etc.) are required to issue and declare e-Fatura and e-Arşiv. It remains voluntary for taxpayers who are not required to use it, unless they are required to declare one-off transactions: invoices exceeding 5 000 TRY or a daily volume exceeding 30 000 TRY, in which case e-Arşiv format is also used.
Previous requirements
To operate in the Turkish electronic invoice system the company must:
- Register with the TRA with their tax number (VKN).
- Submit the required corporate documentation (including the notarial deed of incorporation).
- Obtain a Financial Seal (electronic seal) issued by the Scientific and Technological Research Council of Turkey in coordination with the TRA.
- Configure their systems to send and receive UBL-TR messages through a certified provider or a proprietary solution integrated with the TRA platform.
Operation
Turkey uses a centralized B2B2G model. The issuer sends the invoice to the TRA portal; after passing the validations, the administration forwards it to the recipient. This work flow is replicated for e-Arşiv Fatura (unregistered customers) and for e-İrsaliye (electronic delivery note), which is mandatory for taxpayers with revenues exceeding 10 million TRY.
Invoice Format
- UBL-TR 1.2 TEMEL / TİCARET e-Fatura (domestic market).
- UBL-TR 1.2 (export).
Electronic signature
Document authenticity and integrity is guaranteed by the Financial Seal based on XAdES certificates issued for the legal entity. The signature is mandatory both for sending to the TRA and for archiving.
Invoice Archiving
Sender and receiver must keep the digitally signed e-Fatura, e-Arşiv and e-İrsaliye for 10 years.
Fiscal control
Direct delivery to the recipient is prohibited: all electronic invoices must pass through the TRA platform, which applies syntactic and business controls before making the document available to the recipient.
Frequently Asked Questions
What is the e-Arşiv Fatura?
An electronic invoice issued to customers not registered in the TRA, both B2B and B2C. The issuer declares it on the TRA portal and makes a copy available to the recipient.
What is the e-İrsaliye?
Electronic delivery note whose use is mandatory for companies required to use electronic invoicing and for those who surpass 10 million TRY in annual revenue.
Why do I have to include a QR code in my invoices as of September 2023?
The QR code allows the TRA and the recipient to quickly validate the authenticity of the e-Invoice or e-Arşiv and facilitates manual verification in the event of an audit or physical delivery of the invoice.
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