KDV (VAT) on exports and the refund: the basics for a foreign-owned company in Türkiye

A Turkish company that exports charges no KDV on the export invoice but still pays KDV to its suppliers, and that input tax can be carried forward or claimed back. This guide explains, in plain words, when the exemption applies, how the refund works, which documents the tax office expects and where the SMMM and YMM come in. It is information, not tax advice.

The export exemption: Articles 11, 12 and 32

Under Article 11/1-a of VAT Law No. 3065, export deliveries and services performed for customers abroad are exempt from KDV. Article 12 sets the conditions: the goods must be delivered to a customer abroad or in a free zone and must physically leave the Turkish customs territory. The invoice shows no KDV and refers to the article.

This is a full exemption (tam istisna) under Article 32. The KDV the exporter paid on purchases, transport or packaging stays deductible, and whatever cannot be deducted against domestic sales may be refunded on request. The claim must be made by the end of the second calendar year after the export; a minimum claim amount is set by Presidential decision.

• Goods: customer abroad or in a free zone, goods leave Türkiye
• Services: performed for a customer abroad and used abroad
• Input KDV: deductible, and refundable if not absorbed

When the export counts and which month to declare

For KDV purposes the export is made when the customs declaration is closed (gümrük beyannamesinin kapanması), not when the invoice is issued or the goods leave the warehouse. The exemption is declared in the KDV return of the month in which the declaration closed, so an invoice dated in one month and a closure in the next belong to the later return.

The closing date appears in the customs system and the tax office reads it electronically. Your SMMM needs the declaration number and the closing date to place the sale in the right return. The same declaration later proves the export in the refund file, and its date also starts the 180-day clock for bringing the proceeds into Türkiye.

1. Export invoice without KDV, with the reference to Article 11/1-a
2. Customs declaration registered and the goods leave the country
3. Declaration closed: the export is deemed made
4. Exemption declared in that month’s KDV return

Carry forward, offset or cash: the refund options

Input KDV that the export sales cannot absorb is first carried forward (devreden KDV) and reduces the KDV due on domestic sales. A company with little domestic turnover accumulates a credit, and at that point a refund claim makes sense. The claim is filed for a given month and limited by the KDV attributable to the exported goods.

Two routes exist. Offset (mahsuben iade) applies the credit to the company’s own tax debts, import taxes or social security premiums. Cash refund (nakden iade) pays the amount to the bank account. For goods exports the Communiqué processes offsets without a report regardless of amount, while cash refunds above a threshold need a YMM report, a tax inspection or a security deposit (teminat).

Documents, KDVİRA, delays and the SMMM and YMM

The claim is filed through the GİB internet tax office with a standard refund petition and electronic lists: the sales invoice list, the customs declaration list, the deductible KDV list (indirilecek KDV listesi), the incurred KDV list (yüklenilen KDV listesi) and the refund calculation table. The KDVİRA risk analysis system cross-checks every supplier invoice.

The system produces a control report, and the tax office sends a deficiency letter (eksiklik yazısı) for anything unresolved; the Communiqué gives 30 days to answer before an offset loses its date. No fixed statutory processing time exists, so completeness decides the timeline. Offsets are quicker than cash, and refunds backed by a YMM report move faster than those waiting for an inspection.

• SMMM: prepares the lists, files the return and the claim, answers deficiency letters
• YMM: writes the refund report above the threshold; a full certification contract widens the limits
• Common blocks: a supplier flagged in KDVİRA, invoices missing in e-fatura, an unclosed declaration, a claim above the attributable KDV

Service exports and export-registered deliveries

A service export (hizmet ihracı) is exempt under the same Article 11/1-a when the service is performed for a customer abroad and used abroad, with the invoice issued to that customer. The refund side is stricter: the Communiqué does not pay a refund until the fee has reached Türkiye through a bank, so the bank receipt belongs in the file.

Article 11/1-c covers export-registered deliveries (ihraç kayıtlı teslim). A manufacturer sells to an exporter without collecting KDV; the tax is deferred and cancelled if the goods are exported within three months after the end of the month of delivery, with up to three more months on application. The exporter cannot claim back KDV it never paid.

• Service export: customer abroad, benefit abroad, invoice in the customer’s name, fee received through a bank
• Export-registered purchase: no KDV on the manufacturer’s invoice, three-month export deadline
• Mixed case: a trader buying under 11/1-c claims only KDV on its own overheads

Sources

• mevzuat.gov.tr — VAT Law No. 3065: Articles 11/1-a and 11/1-c (exemptions), 12 (conditions of an export delivery and service), 32 (full exemption and refund)
• lexpera.com.tr — consolidated copy of Law No. 3065 used to read the article texts (mevzuat.gov.tr blocks automated access)
• gib.gov.tr — Revenue Administration: Communiqué amending the VAT General Implementation Communiqué (Series No. 52), 31 October 2024: refund thresholds raised to 50,000 TL
• turmob.org.tr — TÜRMOB copy of the Resmi Gazete text of Series No. 52 (No. 32708), used because gib.gov.tr blocked fetching
• andersen.com — copy of Series No. 55 (Resmi Gazete No. 33007, 4 September 2025): minimum refund claim 10,000 TL, refund document list, exporter cannot claim KDV not paid under Art. 11/1-c
• ticaret.gov.tr — Ministry of Trade: export customs declaration and its closure

Questions