Paying a foreign supplier from a Turkish company: documents the bank needs for an import payment

A Turkish company paying a supplier abroad does not simply order a SWIFT transfer. The bank must file the payment under one of the import payment forms, see the documents behind it and record who is paying for what. This guide explains the four forms used in practice, the document pack for each, the rules of Decree No. 32 and the Import Circular, the questions the bank asks under MASAK rules, and the short explanation letter that makes the file pass at the first attempt.

The four import payment forms

Article 2 of the Import Circular 2020/1 of the Ministry of Treasury and Finance lists the forms in which an import may be paid: letter of credit (akreditif), deferred letter of credit, cash against documents (vesaik mukabili), open account (mal mukabili), their acceptance-credit variants, advance payment (peşin ödeme) and bank payment obligation. In daily practice four matter. Advance payment: the money leaves before shipment, against a proforma invoice. Open account: the goods arrive and clear customs first, the supplier is paid afterwards against the commercial invoice and the customs declaration. Cash against documents: the supplier sends the shipping documents through its bank, and the Turkish bank releases them only once you pay. Letter of credit: your bank undertakes to pay when the supplier presents documents matching the credit terms. Article 1 of the Circular states that import payments are made through banks, in foreign currency or Turkish lira, according to the contract between importer and exporter and international banking practice. The bank therefore asks which form applies before anything else.

Which documents the bank asks for each form

The core pack is the same for every form; what changes is which items exist at the moment of payment. Advance payment: proforma invoice with goods, quantity, price, delivery term (Incoterms 2020 rule and place) and the bank details of the supplier; sales contract or order confirmation if one exists; the customs tariff code (GTİP, the Turkish 12-digit extension of the HS code). Open account: commercial invoice, packing list, transport document (CMR for road, bill of lading for sea, air waybill for air) and the customs declaration (gümrük beyannamesi) showing the goods were imported. Article 3(5) of the Import Circular is explicit: in open account imports the bank executes the transfer on the basis of the customs declaration date and number the company declares in writing. Cash against documents and letters of credit: the documents come through the banks, so your file is the contract, the proforma and the application form of the bank. Keep supplier name, amounts, currency and goods description identical everywhere; the bank compares line by line.

Who may pay, from what, and the third-party problem

Article 9 of Decree No. 32 provides that transfers abroad for import and transit trade are made by banks. Article 3 of the Import Circular lists the sources: bank resources, the foreign-currency deposit account (DTH) of the importer, a credit card, unsold export proceeds of the importer, and loans under the capital movement rules. Banks may not issue a cheque to pay an import. The thread through these rules: the importer of record pays from its own account and the bank records the payment against it. A payment ordered by another company, a shareholder or a related entity breaks that link: the bank asks why, may require the contract behind it, and often declines. Article 5 of the Circular recognises one case expressly: a factoring company resident in Türkiye paying the supplier before import, on presentation of both factoring contracts. Article 15 of Law No. 5549 makes acting for another person without written declaration an offence, so if the money belongs to someone else, say so in writing.

What the bank asks under MASAK rules, timing and refusals

Beyond the trade documents the bank fills in its transfer record: counterparty name and address, beneficiary bank and country, purpose, invoice number and your relationship with the supplier. Under Article 24 of the MASAK Regulation on Measures an electronic transfer of 30,000 TL or more must carry sender name, account number or reference and at least one further identifier, plus the beneficiary name and account; the bank verifies them. The message is screened against sanctions and risk lists at the Turkish bank and every correspondent. Timing: a transfer ordered before the branch cut-off hour usually leaves the same working day; the supplier sees the funds one to three working days later. Common refusals: the supplier or its bank sits in a jurisdiction the correspondent will not serve; no GTİP or goods description; amount, currency or beneficiary differ between proforma, invoice and order; the payer is not the importer; the beneficiary account is in another name; the purpose field names a third party. Each is fixed by documents.

The cover letter and the customs link

What makes a file pass is one page in Turkish to the branch stating, in order: the paying company and its tax number; the supplier and its country; invoice or proforma number and date; the goods and their GTİP; amount and currency; the Incoterms 2020 rule and named place, for example FCA Bologna; the route, for example Bologna, Italy to İstanbul, Türkiye by road under CMR; the payment form; for open account, the declaration date and number. The same facts go into the transfer açıklama. The customs link matters for two reasons. First, under Article 3(6) of the Import Circular the bank issues on request a letter or the Belge ID created under Ministry of Trade rules, which is how customs sees the price was paid. Second, the Resource Utilisation Support Fund (KKDF) is levied on deferred-payment imports such as open account; an advance payment escapes it only if recorded through the transfer notification form (transfer bildirim formu) before the declaration is registered. Ask your customs broker.

Sources

• hmb.gov.tr — Ministry of Treasury and Finance: Import Circular 2020/1 (payment forms, sources of payment, customs declaration reference)
• mevzuat.gov.tr — Decree No. 32 on the Protection of the Value of Turkish Currency, Article 9 (import transfers made through banks)
• masak.hmb.gov.tr — MASAK: Regulation on Measures, Article 24 (electronic transfer messages, sender and beneficiary data)
• iccwbo.org — International Chamber of Commerce: Incoterms 2020 rules

Questions