At the Onset of the Financial Holiday…

Gizem Şimşek co-authored this article.

Pursuant to Article 1 of Law No. 5604 on the Establishment of a Financial Holiday (“Law”), a financial holiday is observed annually from July 1 to July 20 (inclusive). Accordingly, the financial holiday for the year 2025 will take place between July 1, 2025, and July 20, 2025.

Within the scope of the Law;

• Legal and administrative deadlines falling on the last day of the financial holiday are extended by seven days, starting from the day following the last day of the financial holiday.

• Deadlines that expire within five days following the end of the financial holiday shall be deemed to have expired at the end of business hours on the fifth day following the last day of the financial holiday.

Detailed provisions regarding the implementation of the financial holiday are regulated by the Ministry of Treasury and Finance through the General Communiqué No. 1 on the Implementation of the Financial Holiday (“Communiqué”). In this regard, the key points to consider with respect to ongoing or suspended procedures during the financial holiday and the extension of deadlines are summarized below:

1. Deadlines Not Covered by the Financial Holiday

Pursuant to paragraph 7 of Article 1 of the Law, the following deadlines are excluded from the scope of the financial holiday:

• Special Consumption Tax (SCT),

• Banking and Insurance Transactions Tax (BITT),

• Special Communication Tax,

• Lottery Taxes,

• Taxes, fees, and charges assessed and/or collected by customs administrations, special provincial administrations, and municipalities.

Additionally:

• Submission and payment deadlines for notifications related to the Resource Utilization Support Fund (“RUSF”) deductions,

• Payment deadlines for public receivables under Law No. 6183 on the Procedure for the Collection of Public Receivables, in cases where special laws do not specify payment terms, shall not be extended due to the financial holiday.

2. Deadlines Extended Due to the Financial Holiday

Pursuant to the provisions of the Communiqué, the following deadlines are extended by seven days, starting from the day following the last day of the financial holiday:

• Submission deadlines for declarations required to be filed within the statutory period in self-assessed taxation,

• Payment deadlines for taxes, tax penalties, and late payment interests assessed by additional, ex officio or administrative assessments falling due during the financial holiday,

• Application deadlines for reconciliation or penalty reduction requests regarding assessed taxes and penalties,

• Deadlines for providing documents requested within the scope of information obligations by the Ministry of Treasury and Finance or tax offices when such deadlines fall during the financial holiday.

3. Deadlines That Do Not Run During the Financial Holiday

The following deadlines shall be suspended during the financial holiday:

• Accounting record and notification deadlines and litigation deadlines determined under the Tax Procedure Law No. 213 (“TPL”),

• Other notification deadlines prescribed under the TPL,

• Litigation deadlines against additional, ex officio, or administrative assessments overlapping with the financial holiday.

4. Books and Documents Submission – Tax Audit

According to the TPL;

• It is not permitted to initiate tax audits by authorized persons during the financial holiday. During this period, taxpayers cannot be requested to submit books or documents.

• If the audit started prior to the financial holiday, it may continue; however, during the financial holiday, taxpayers cannot be requested to submit documents, nor can they be summoned to sign reports resulting from the audit.

5. Requests for Information and Notifications

During the financial holiday, except for tax and penalty notices and offset requests, information requests to taxpayers and responsible parties cannot be issued.

6. Deadlines Expiring Within Five Days Following the Financial Holiday

Legal and administrative deadlines expiring within five days following the end of the financial holiday shall be deemed to have expired at the end of business hours on the fifth day after the financial holiday.

7. Payment Deadlines for Taxes With Extended Declaration Deadlines

For taxes based on declaration, whose filing deadlines are extended due to the financial holiday, the payment deadline is extended until the close of business on the first working day following the last day of the extended declaration period, provided that the payment remains within the same month.

8. Cases Where Deadlines Are Not Extended Due to the Financial Holiday

According to the Communiqué, no extensions shall be granted due to the financial holiday for the following cases:

1. Submission and payment deadlines for the (5) No. VAT declaration related to sales via enforcement (Value Added Tax General Application Communiqué I/B-6.2.2),

2. VAT payment deadlines arising from auction sales by official institutions that do not have a continuous declaration obligation,

3. Submission and payment deadlines for stamp tax and fees collected by notaries and declarations No. (1) and (4) under Law No. 492 on Fees.

In conclusion, it is of utmost importance for taxpayers and professional representatives to carefully assess their transactions and obligations within the scope of the financial holiday, correctly analyze which deadlines are extended or not, and meticulously plan their calendars to avoid conflicts with deadlines following the financial holiday.