Beneficial owner (UBO) notification in Türkiye: GİB filing, bank identification and share transfers

In Türkiye the beneficial owner (gerçek faydalanıcı) of a company is reported twice: once to the Revenue Administration (GİB) under Tax Procedure Law General Communiqué No. 529, and again to every bank, which identifies the owner itself under the anti-laundering Measures Regulation. This guide explains who counts as a beneficial owner, who files, when, through which channel, and how to keep both records consistent. Status checked on 13 November 2026.

Who counts as a beneficial owner

A beneficial owner is always a natural person: the individual who ultimately controls a company or has ultimate influence over it. Article 5 of Communiqué No. 529 and Article 17/A of the Measures Regulation use the same three-step test, applied in order until someone is found.

1. Natural persons holding more than 25% of the shares.
2. If there is none, or doubt that the holder is the real owner, the persons who ultimately control the company.
3. If still nobody is found, the person or persons with the highest executive authority.

“More than 25%” means exactly 25% does not meet the first step. Holdings through other companies count: GİB Circular No. 145 multiplies the percentages, so 80% of a parent that owns 40% gives 32%. Control can also come from contracts, family ties or the right to appoint the board majority.

Who must notify GİB and when

Communiqué No. 529 entered into force on 13 July 2021. It applies to corporate taxpayers such as Ltd and A.Ş. companies, including those in liquidation, and to representatives of partnerships and certain foreign trusts managed from Türkiye. Banks, notaries and other obliged parties report only when GİB asks them about their customers.

The one-month rule in Article 6(3) is the deadline that usually matters in practice: it runs from the date of the change, not from the next tax return. Agree with your SMMM which filing will carry the update.

What the GİB filing contains and how it is sent

Article 7 lists the data: each beneficial owner’s name and surname, nationality, identity numbers and address, phone, fax and e-mail if any, and the reason he or she is a beneficial owner, for example share ownership or control. The notification is electronic only, through İnternet Vergi Dairesi; paper notifications are not accepted.

For companies, the “Gerçek Faydalanıcıya İlişkin Bilgiler” tab sits in the attachments to the corporate provisional tax return. According to GİB’s announcement, a company that has already filed and has no changes ticks a box; otherwise it enters all beneficial owners, not only the new one.

• Keep the supporting records for five years.
• Late or wrong filings fall under the penalty provisions of Tax Procedure Law No. 213.
• Foreign owners need a passport number and a current address.

How the bank identifies the beneficial owner

A Turkish bank does not rely on your GİB filing. Under Article 17/A of the Measures Regulation it must identify the beneficial owner of a legal-entity customer itself, using the same three steps, and obtain and verify the person’s identity. A notarised signature circular containing identity details may be used. Under Article 7 it also checks the company against the trade registry or the TOBB database.

If a shareholder holding more than 25% is itself a company, the bank identifies that company too. For foreign shareholders the regulation lets the bank use open-source information from equivalent foreign registries, so expect questions about every layer of the chain.

• Registry record and Trade Registry Gazette notices.
• Share ledger or shareholder list and an ownership chart.
• Passport and address of each beneficial owner.
• A signed beneficial owner declaration on the bank’s form.

Consistency and changes after a share transfer

The texts we read give banks no access to the GİB filing, but GİB may ask the bank for its customer data. The same people, percentages and addresses should therefore appear in the share ledger, the registry record, the tax return attachment and the bank file. A mismatch is a common reason for a bank to reopen a KYC review.

1. Complete the transfer with the formalities for your company type.
2. Update the share ledger and, where required, the trade registry record.
3. Notify GİB within one month of the change.
4. Send the bank the new ownership documents before it asks.

If the bank cannot complete identification it may decline transactions; the regulation has a separate article on refusing transactions and ending relationships. Our guide on bank document requests after opening covers that process; to check your own file, contact us.

Sources

• turmob.org.tr — Resmî Gazete No. 31540 of 13.07.2021: Tax Procedure Law General Communiqué No. 529 on beneficial owner notification (gib.gov.tr and mevzuat.gov.tr block automated access, so this copy was used)
• alomaliye.com — full text of Communiqué No. 529: scope, deadlines, İnternet Vergi Dairesi filing
• alomaliye.com — GİB Tax Procedure Circular No. 145 (05.09.2022) on the beneficial owner definition, with examples
• alomaliye.com — GİB announcement (07.10.2021): beneficial owner tab in the corporate provisional tax return
• lexpera.com.tr — Regulation on Measures against Laundering and Terrorist Financing, consolidated text, Articles 3, 7, 17 and 17/A
• ms.hmb.gov.tr — Ministry of Treasury and Finance / MASAK guide on identifying the beneficial owner

Questions