Contact

Tax Advisory

Tax Debt Restructuring and Deferral

Assessing the options of deferral and payment by instalments, settlement, voluntary disclosure, invitation to explain and penalty reduction for tax debts and penalties, preparing the application file and monitoring the payment plan.

Contact form
Top view of an office desk with a calendar, a notebook and a smartphone

Overview

Restructuring arrangements (yapılandırma), which allow part of the interest and penalties on tax debts to be written off and the debt to be paid in instalments, are introduced by separate laws for a specific period, and their application periods are limited. As of November 2026, there is no such restructuring law open for applications.

Even in periods without such a law, there are ways under the law to reduce the burden of tax debts and penalties or to spread payment over time: deferral and payment by instalments of public receivables (Law No. 6183 on the Collection of Public Receivables, Art. 48), voluntary disclosure (pişmanlık) and correction (ıslah) (Tax Procedure Law No. 213, Art. 371), invitation to explain (izaha davet) (Tax Procedure Law No. 213, Art. 370), settlement (uzlaşma) (Tax Procedure Law No. 213, Additional Art. 1 and Additional Art. 11) and penalty reduction (Tax Procedure Law No. 213, Art. 376). Each of these options has different conditions and time limits.

KEYBIZ CPAs & Advisors reviews the company’s tax office statement of debts and its return records to determine which options can be applied, prepares the application petitions and their attachments, and monitors the payment plan and instalment dates. For work carried out during a tax inspection, see our Preparing for a Tax Inspection page.

Options for Debts and Penalties

What It ProvidesTime Limit and Condition
Deferral and Payment by InstalmentsPostponement of a public debt, or its payment in instalments, with interest charged (Law No. 6183, Art. 48)Payment on the due date would put the debtor in serious difficulty, a written request and a guarantee; a maximum of 72 months
Voluntary Disclosure and CorrectionNo tax loss penalty is imposed (Tax Procedure Law No. 213, Art. 371)Disclosure on one’s own initiative; before a tip-off, an inspection or referral to the assessment commission; 15 days for filing and payment
Invitation to ExplainIf the explanation is found sufficient, no inspection is carried out; if not, and the return is filed and payment made in time, the tax loss penalty is imposed at a rate of 20% (Tax Procedure Law No. 213, Art. 370)30 days from service of the letter of invitation to explain
Pre-Assessment SettlementSettlement on tax loss, irregularity and special irregularity penalties to be imposed on the basis of a tax inspection (Tax Procedure Law No. 213, Additional Art. 11)Before assessment; if no settlement is reached, post-assessment settlement cannot be requested
Post-Assessment SettlementSettlement on penalties relating to taxes assessed additionally, ex officio or by the administration (Tax Procedure Law No. 213, Additional Art. 1)30 days from service of the tax notice (vergi ihbarnamesi)
Penalty ReductionHalf of the tax loss, irregularity and special irregularity penalties is waived (Tax Procedure Law No. 213, Art. 376)Application within 30 days of service of the notice; payment on the due date, or within three months with a guarantee; no lawsuit filed

Current texts of the VUK and Law No. 6183 on mevzuat.gov.tr (November 2026).

Changes to Deferral in 2026

Maximum term and guarantee threshold: Law No. 7582 increased the maximum deferral period in Article 48 of Law No. 6183 from 36 months to 72 months, and the deferral amount for which no guarantee is required from TRY 50,000 to TRY 1,000,000. (Law No. 7582, Art. 1) By Presidential Decision, this amount has been set at TRY 10,000,000. (Presidential Decision No. 11414)

Low-interest deferral scheme: The General Communiqué on Collection (Tahsilat Genel Tebliği) (Series B, No. 20) allowed public receivables falling due on or before 5.6.2026 and followed up by tax offices to be paid in instalments at an annual deferral interest rate of 29%. The application period for this scheme ended on 31.8.2026. Applications after this date and debts falling due after 5.6.2026 are assessed under the provisions of the General Communiqué on Collection (Series A, No. 1). (General Communiqué on Collection, Series B, No. 20, Art. 3, 4, 6, 13)

Existing payment plans: For debts deferred under this Communiqué, failure to pay, or partial payment of, no more than two instalments a year on time does not cancel the deferral if these instalments are paid with interest within the period of the next instalment. (General Communiqué on Collection, Series B, No. 20, Art. 12)

Deferral and Instalment Process

  1. Preparing the Statement of Debts

    The debts at the tax office are broken down by type, due date and late payment surcharge (gecikme zammı). A late payment surcharge applies to unpaid public receivables from the due date. (Law No. 6183, Art. 51)

    • Tax office statement of debts
    • List of overdue debts and debts not yet due
    • Separate listing of assessments under litigation or at the settlement stage
  2. Determining the Appropriate Option

    Depending on the source of the debt, it is assessed which of the options of deferral, voluntary disclosure, settlement or penalty reduction can be applied. If an inspection or a tax notice is involved, the start of the 30-day periods for settlement and penalty reduction is determined.

  3. Preparing the Deferral Request

    Deferral is granted, with interest charged, by decision of the creditor administration or the authorities it has empowered, on condition that the debtor makes a written request and provides a guarantee. (Law No. 6183, Art. 48) The request is prepared together with financial statements and information showing the company’s ability to pay.

  4. Guarantee

    If the total of the debtor’s deferred debts at the same collection office does not exceed the amount set by the President, no guarantee is required. (Law No. 6183, Art. 48; Presidential Decision No. 11414) For debts above this amount, the assets to be provided as a guarantee are prepared.

  5. Monitoring the Payment Plan

    If the deferral conditions are not complied with, the public receivable becomes immediately due. (Law No. 6183, Art. 48) For this reason, instalment dates and the payment dates of new-period taxes are monitored together.

Frequently Asked Questions

Is There a Tax Restructuring Currently Open for Applications?

As of November 2026, there is no restructuring law open for applications that writes off part of the interest and penalties. The application period for the low-interest deferral scheme introduced in 2026 also ended on 31.8.2026. (General Communiqué on Collection, Series B, No. 20, Art. 4) The general deferral and instalment route for tax debts remains open. (Law No. 6183, Art. 48)

For How Many Months at Most Can a Tax Debt Be Paid in Instalments?

Under Article 48 of Law No. 6183, the deferral period is a maximum of 72 months. This period was increased from 36 months to 72 months by Law No. 7582. The number of instalments granted in a specific request is determined according to the principles in the general communiqués on collection.

Is a Guarantee Required for Deferral?

Under the Law, deferral is granted on condition that a guarantee is provided. However, if the total of the debtor’s deferred debts at the same collection office does not exceed the set amount, no guarantee is required; this amount has been set at TRY 10,000,000 by Presidential Decision No. 11414. (Law No. 6183, Art. 48)

What Does Voluntary Disclosure Provide?

For taxes based on a return, no tax loss penalty is imposed on a taxpayer who, on its own initiative, reports by petition a situation that has led to a tax loss, if the conditions are met. The disclosure must be made before a tip-off and before a tax inspection begins or the matter is referred to the assessment commission, the return must be filed within 15 days, and the tax must be paid within 15 days together with an amount calculated at the late payment surcharge rate. (Tax Procedure Law No. 213, Art. 371)

Can the Principal Tax Be the Subject of Settlement?

No. Under the text in force, the subject of pre-assessment and post-assessment settlement is the tax loss penalties relating to the assessed taxes, and irregularity and special irregularity penalties. (Tax Procedure Law No. 213, Additional Art. 1, Additional Art. 11) Penalties imposed where a tax loss is caused by the acts listed in Article 359 of the VUK, and penalties imposed on those participating in these acts, are outside the scope of settlement. The time limit for filing a lawsuit against the principal tax runs independently of the settlement request. (Tax Procedure Law No. 213, Additional Art. 1, Additional Art. 7, Additional Art. 11)

Who Can Benefit from Penalty Reduction?

For taxes and penalties assessed additionally, ex officio or by the administration, half of the tax loss, irregularity and special irregularity penalties is waived for a taxpayer who applies to the tax office within 30 days of service of the notice and states that it will pay on the due date or, by providing a guarantee, within three months of the due date. The reduction is not available if the taxes and penalties are not paid in time or are challenged in court. This reduction does not also apply to penalties that have been settled. (Tax Procedure Law No. 213, Art. 376, Additional Art. 9)

What Should Be Done If a Letter of Invitation to Explain Arrives?

An explanation is given within 30 days of service of the letter of invitation to explain. If the explanation is found sufficient, no inspection is carried out for the finding concerned. If it is not found sufficient, and within 30 days of service of the evaluation letter the missing returns are filed or the return is corrected and the taxes are paid together with the late payment surcharge, the tax loss penalty is imposed at a rate of 20%. (Tax Procedure Law No. 213, Art. 370)

Ask about Tax Debt Restructuring and Deferral

Fill in the form to contact us. The service field is preselected for this page and can be changed.