Tax Procedure Law General Communiqué (Serial No: 592) — Competent Reconciliation Commissions for Tax Penalties
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This communiqué, issued by the Ministry of Treasury and Finance (Revenue Administration), establishes the framework for determining which reconciliation commission has jurisdiction over disputes involving tax loss penalties, irregularity penalties, and special irregularity penalties under the Tax Procedure Law (Law No. 213). It entered into force on its publication date of March 28, 2026. For tax loss penalty disputes, the competent reconciliation commission is determined based on the highest single penalty amount appearing across all tax/penalty notices for the taxpayer. Cases exceeding local tax office commission thresholds escalate sequentially to the provincial treasury commission, the Tax Offices Coordination Reconciliation Commission, or the Central Reconciliation Commission. For irregularity and special irregularity penalties, only penalties exceeding 5,000 TL (adjusted to 40,000 TL for 2026 via the annual revaluation rate) are eligible for reconciliation. The 40,000 TL threshold will be updated each year per the revaluation rate under Article 298 of the Tax Procedure Law and published in the Official Gazette by the Ministry. When a taxpayer files for reconciliation on both tax loss penalties and irregularity penalties simultaneously, the tax loss penalty amounts determine which commission has jurisdiction, and all related penalty disputes are consolidated before that single commission to ensure procedural unity.
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Key Changes
- Reconciliation threshold for irregularity and special irregularity penalties set at 40,000 TL for 2026 (statutory base: 5,000 TL, adjusted annually by revaluation rate)
- Jurisdiction of competent reconciliation commission for tax loss penalties is determined by the highest single penalty amount across all tax/penalty notices for the same taxpayer
- When multiple tax loss penalties exist across different years, the commission covering the highest-amount notice has jurisdiction over all related disputes (unity of reconciliation principle)
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Obligations
What this law requires
Determine jurisdiction of reconciliation commissions for tax loss penalty disputes based on the highest single penalty amount appearing across all tax/penalty notices for the taxpayer, escalating sequentially to provincial treasury commission, Tax Offices Coordination Reconciliation Commission, or Central Reconciliation Commission as applicable.
Consolidate all related penalty disputes (tax loss penalties and other penalties) before a single reconciliation commission determined by the highest tax loss penalty amount to ensure procedural unity.
Apply the 5,000 TL threshold (40,000 TL for 2026) for irregularity and special irregularity penalties eligible for reconciliation; exclude penalties at or below this threshold from reconciliation scope.
Update and publish annually the revaluation threshold amount for irregularity and special irregularity penalties in the Official Gazette by the Ministry of Treasury and Finance, calculated according to Article 298 revaluation rate of the Tax Procedure Law.
When determining reconciliation commission jurisdiction for irregularity and special irregularity penalties, use the threshold amount valid on the date of notice issuance (not the date of application), adjusted per Article 414 of the Tax Procedure Law.