Ownership structure chart for a Turkish bank: from the company to the beneficial owner
When a company with foreign shareholders opens or updates a bank account in Türkiye, the bank asks for an ownership structure chart that runs from the Turkish company up to the individuals who own or control it. This guide explains how to calculate direct and indirect percentages, which documents back each level, how foreign papers are apostilled and translated, and how to keep the chart consistent with the GİB filing and the bank form. Status checked on 14 November 2026.
What the bank needs to see on the chart
A Turkish bank must identify the beneficial owner of a corporate customer itself. Article 17/A of the Measures Regulation applies three steps in order: natural persons holding more than 25% of the shares, then persons with ultimate control, and if nobody is found, the top executive registered in the trade registry. The beneficial owner is always a natural person.
When a shareholder is another company, the bank has to look through it. Under Article 17/A(7) it identifies every legal-person shareholder above 25% and may verify foreign ones through the open registries of their home country. The chart is the page that lets the compliance officer follow that path.
- Every entity from the Turkish company up to the individuals
- The share percentage at each link
- Country, registration number and date of each entity
- Who controls each entity, if not the owners
Direct and indirect percentages: a worked example
Draw the chart from the Turkish company upwards until every branch ends with a person. Indirect holdings are found by multiplying the percentages along a branch. GİB Circular No. 145 uses the same method: a person holding 40% of a parent that owns 80% of the company holds 32%.
| Level | Entity | Shareholder | Share | Effective share |
|---|---|---|---|---|
| 1 | Örnek Ltd. Şti. (Türkiye) | Alpha Holding B.V. | 70% | 70% |
| 1 | Örnek Ltd. Şti. | Person C | 30% | 30% direct |
| 2 | Alpha Holding B.V. | Person A | 60% | 70 × 60 = 42% |
| 2 | Alpha Holding B.V. | Beta Ltd | 40% | 70 × 40 = 28% |
| 3 | Beta Ltd | Person B | 100% | 28% |
All three individuals exceed 25%, so all three are beneficial owners. Exactly 25% would not meet the first step. Control through voting agreements or the right to appoint the board majority must still be shown. Beta Ltd itself holds 28% indirectly, so the bank identifies it as a legal-person shareholder as well.
Documents behind each level of the chain
Every box on the chart needs a document behind it. Under Article 11 of the Measures Regulation a foreign company is identified with the home-country equivalents of Turkish registry documents, certified by a Turkish consulate or apostilled. Each bank sets its own list and how recent the papers must be, so confirm it before ordering.
- Certificate of incorporation and certificate of good standing
- Register extract with directors and registered office
- Shareholder register or share certificates
- Director list and the authority of the signatory
- Passport and address proof of each individual
For a trust, the trustee declares in writing before the transaction that it acts for the trust, and the settlor, beneficiaries, any protector and the person with ultimate control are identified. A nominee must name the person behind him: Article 15 of Law No. 5549 requires a written declaration. Foundations are followed to their ultimate controllers.
Apostille, sworn translation and notarisation
If the issuing country is a party to the Hague Apostille Convention of 1961, its competent authority adds an apostille, and under Article 3 no other legalisation may be required. Otherwise the document is legalised by that country’s authorities and the Turkish consulate. A shareholder register kept by the company itself is usually notarised first, then apostilled.
Under Article 5 the apostille confirms the signature, the signer’s capacity and the seal, not the content, so the bank still checks dates and figures. In Türkiye a translator sworn before a notary translates the document and the notary certifies the translation (Notaries Law No. 1512, Article 103).
- Obtain the original or certified copy abroad
- Notarise company-issued papers where needed
- Apostille or consular legalisation
- Sworn Turkish translation certified by a notary
Signing, dating and matching the GİB and KYC records
No Turkish legal text we read prescribes a format for the chart, so each bank sets its own. In practice the chart states the date at which the percentages apply, is dated and is signed by the person authorised in the signature circular. Banks often ask for it together with their own beneficial owner declaration (KYC form).
The same names, percentages and addresses should appear in the chart, the bank form, the share ledger and the GİB filing under Communiqué No. 529, which is updated within one month of a change. See our guide on beneficial owner notification.
- Percentages at one level that do not add up to 100%
- A branch ending at a company, not a person
- Documents older than the bank accepts
- Translation that omits the apostille page
- Names spelled differently from passports
Sources
- lexpera.com.tr — Regulation on Measures against Laundering and Terrorist Financing, consolidated text: Article 11 (foreign legal persons and trusts) and Article 17/A (beneficial owner); mevzuat.gov.tr blocks automated access, so this copy was used
- turmob.org.tr — GİB Tax Procedure Circular No. 145 (05.09.2022) on the beneficial owner definition, including the indirect holding example
- hcch.net — Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation (Apostille), full text
- alomaliye.com — MASAK guide on identifying the parties to trusts established abroad (01.06.2021), copy of the ministry PDF
Questions
Who prepares and signs the ownership chart?
The company prepares it, usually on its letterhead, and the person authorised in its signature circular signs and dates it. The bank may add its own form; its requirements prevail for its file.
How are indirect percentages calculated?
Multiply the percentages along each branch. GİB Circular No. 145 gives the example of 40% of a parent that owns 80%, which equals 32% of the company.
Is an apostille enough for every country?
Only for documents from countries that are party to the Hague Apostille Convention. Documents from other countries need legalisation by their authorities and the Turkish consulate.
Do the foreign documents have to be translated?
The Measures Regulation lets the bank ask for notarised Turkish translations on a risk basis. Ask the bank which documents it wants translated before ordering.
What if a trust is in the chain?
The trustee declares in writing that it acts for the trust, and the bank identifies the settlor, beneficiaries, any protector and the person with ultimate control, using apostilled or consulate-certified trust documents.