How to Get a VAT Refund on Exports in Turkey: Exporter’s Checklist

If you invoice your foreign buyer without charging VAT but pay VAT during production and procurement, the way to recover that burden is a VAT refund on exports. A VAT refund on exports is the return to the exporter, by offset or in cash, of the VAT incurred on an export delivery exempted under Article 11/1-a of VAT Law No. 3065 that cannot be recovered through deduction. This right does not work automatically. It requires filing in the correct period, complete documents and consistent lists.

In this article we focus only on exports of goods with a customs declaration: the conditions of the exemption, the filing period, the document list, the VAT refund lists, the cash refund limit and the refund method specific to manufacturers. We explain the general logic of VAT refunds and all refund methods separately in our What is a VAT refund guide.

Which deliveries does the export exemption cover?

The export exemption applies to deliveries that meet both conditions in Article 12 of the VAT Law. The delivery must be made to a customer abroad, to a buyer in a free zone or to duty-free shops, and the goods must leave the Turkish customs territory and reach a foreign country or a free zone. If either condition is missing, the transaction does not fall within the exemption.

A customer abroad is a buyer whose residence, place of business, legal seat and business center are abroad. A Turkish company’s branch, office or representative operating independently in its own name abroad also falls within this definition. The export invoice is issued in the name of this buyer; an invoice issued in the name of an intermediary company in Turkey cannot serve as the basis for the exemption.

We would like to draw particular attention to one point. Not every transaction regarded as an export under foreign trade legislation gives rise to the export exemption for VAT purposes. The VAT General Implementation Communiqué states clearly that transactions not meeting the conditions in Article 12 cannot be treated as within the exemption.

Where exports stand among transactions within the scope of full exemption

Transactions within the scope of full exemption are those in which the sale is made without VAT but the right to deduct and recover the VAT paid for that sale is preserved. Exports of goods are the most common example of this group. They are shown on the return in the table of the same name: the Transactions Within the Scope of Full Exemption table in the “Exemptions-Other Transactions Giving Rise to a Refund Right” tab, on line code 301.

The export value is entered in the “Delivery and Service Amount” column of this line, and the VAT embedded in the exported goods in the “VAT Incurred” column. If you will not request a refund, “0” is entered in the VAT incurred field and the tax paid continues to be used through deduction.

In which period are exports declared?

Exports of goods are declared in the tax period that includes the closing date of the customs declaration. For exports processed at an inland customs office, the date on which the declaration is closed at the border customs office applies. Even if the invoice was issued in an earlier month, the filing period does not change.

An export value denominated in foreign currency is converted into TL at the Central Bank of the Republic of Turkey buying rate published in the Official Gazette on the closing date of the customs declaration. If no rate was announced that day, the rate in the first Official Gazette before the closing date is used. For deliveries to a free zone made without a customs declaration, the date on which the free zone transaction form is approved is treated as the export date.

A mismatch we often encounter in practice begins here. If the declaration for a shipment dispatched at month-end closes in the first days of the next month, the export goes into that next month’s return. Checking this difference between the accounting entry and the VAT filing at the monthly close prevents the refund file from requiring corrections later.

Customs declaration and other documents: the exporter’s checklist

The section of the VAT General Implementation Communiqué on exports of goods lists the documents required in a refund request one by one. Your checklist consists of these six items:

• Standard refund request petition
• Sales invoice list
• Customs declaration or a list containing the declaration details
• Deductible VAT list for the period in which the export is declared
• List of VAT incurred
• Calculation Table of VAT Requested for Refund

If you choose to submit a list instead of the customs declaration, the list must include the date and number of the declaration, the type, quantity and value of the goods, the customs gate, the destination country, the manufacturer’s name if any, and the completion and exit dates. Documents obtained electronically do not need to be submitted separately on paper; the Internet Tax Office list receipt attached to the petition is sufficient.

Documents accepted in place of a customs declaration

Not every export is made with a conventional customs declaration. The Communiqué accepts the following documents in place of a customs declaration for different export channels:

• For exports to a free zone, the free zone transaction form
• For exports by post or express courier, the electronic commerce customs declaration approved electronically by the customs directorate
• For deliveries to duty-free shops, the bonded warehouse declaration containing customs approval that the goods have been placed in the shop or warehouse
• For border trade, the customs declaration or its list together with a one-time border trade authorization certificate

If a mismatch in amount or quantity arises between the invoice and the customs declaration, the tax office requests information from the relevant customs directorate and acts on the outcome. This correspondence can hold the file up for weeks. That is why we check, before submission, that the description of goods, quantity and foreign currency amount on the invoice match the declaration exactly.

How are the VAT refund lists prepared?

The VAT refund lists are the numerical backbone of your refund request and are submitted electronically through the Internet Tax Office. The four lists must corroborate one another: the sales invoices list shows the sales giving rise to the refund right, the deductible VAT list shows all deductions for the period, the VAT incurred list shows the tax attributable to exports, and the calculation table shows the refund amount.

The VAT incurred list shows, document by document, which input the amount requested for refund comes from: finished goods, raw materials, auxiliary materials, services purchased, overheads or depreciable fixed assets (ATİK, assets used for more than one year, such as machinery and vehicles). Even purchases from the same supplier are entered on separate lines per document. The calculation table, based on this list, summarizes direct inputs, the share allocated from overheads and the ATİK share.

What goes into the VAT incurred calculation?

The calculation is built in a set order. First, the VAT on purchases that are direct inputs to the exported goods is taken. Then the share of overheads such as telephone, rent, electricity, accounting and similar expenses attributable to exports is added. Allocating a share from ATİK comes last and is possible only up to the maximum refundable amount.

The maximum refundable amount is calculated by applying the general VAT rate to the value of transactions giving rise to a refund right in the period. If direct input VAT exceeds this amount, the excess is refunded only on the basis of a tax inspection report. VAT on expenses unrelated to exports does not enter the calculation at all. VAT you did not pay cannot be refunded either; the value of goods you purchased under export registration or without VAT is deducted from the export value in calculating the maximum amount.

Refund by offset and in cash: which limits apply to exports?

You can have a refund receivable arising from exports of goods offset against your debts or request it in cash. For offset refund requests, the Communiqué does not require a tax inspection report, a YMM report or collateral, whatever the amount, if the documents are complete. This is the fastest route for an exporter with regular tax and SGK premium debts.

For cash refunds, however, there is a limit. Under the VAT General Implementation Communiqué issued by the Revenue Administration (GİB), cash refund requests arising from exports of goods not exceeding 50,000 TL are fulfilled without a report or collateral. This limit was raised from 10,000 TL to 50,000 TL from 31.10.2024 by Communiqué Serial No. 52. The portion exceeding the limit is paid on the basis of a tax inspection report or a YMM certification report; if you provide collateral, the refund is made first and the collateral is released according to the report’s outcome.

Since comparing routes such as reports, collateral and preliminary checks is the subject of our companion article, we do not repeat it here. The exporter’s real question is often this: how does VAT accumulating while the refund is delayed affect cash flow? On this point, the approaches in our how to close a VAT deficit article also offer guidance for exporters.

Refund based on export value for manufacturers

There is another, less well-known option for manufacturer-exporters. Under this practice, based on the authority in Article 32 of the VAT Law, manufacturers that directly export the goods they produce can request a refund without calculating the VAT incurred item by item. According to the Revenue Administration (GİB) Communiqué, the refund is made up to 10% of the export value and limited to the amount of VAT carried forward.

The practice is optional and is open only to holders of a manufacturer’s certificate. Goods you produce, or have produced by a subcontractor, within the capacity stated in the manufacturer’s certificate are covered; goods you buy ready-made on the market and export are not. The declaration is made on line code 338 of the Transactions Within the Scope of Full Exemption table.

The document list changes slightly under this method. In addition to the standard petition, the sales invoices list, the customs declaration and the calculation table, a chamber membership certificate, the manufacturer’s certificate and the deductible VAT lists for the last 24 periods before the export period are required. Under this method, the cash refund limit is 50,000 TL, or 100,000 TL for those with a YMM full certification agreement concluded on time.

Which method is more advantageous depends on the proportion of VAT-bearing inputs in the product cost. For a producer whose inputs are largely subject to VAT, the VAT incurred calculation may produce a higher refund. The two methods cannot be used together for the same export; however, a manufacturer that chooses this method in one period can return to the VAT incurred method in other periods.

VAT refund on exports in 6 steps: the application flow

The flow below summarizes how we build the file for an export of goods with a customs declaration:

• Step 1: Match exports with customs declarations at the monthly close. Check the closing date and TL equivalent of the declaration corresponding to each invoice; this date determines the period.
• Step 2: Choose the method. Decide whether to request a refund based on VAT incurred or, if you are a manufacturer, based on export value; both cannot be chosen for the same export.
• Step 3: Calculate the VAT incurred. Calculate direct inputs, the overhead share and the ATİK share in that order and compare them with the maximum refundable amount.
• Step 4: Show the exemption and the VAT incurred on the return. Complete line code 301 or 338; if the VAT incurred field is left blank, the filing is not treated as a refund request.
• Step 5: Submit the VAT refund lists and file the petition. Submit the lists through the Internet Tax Office, and in the standard refund request petition choose offset, cash or both.
• Step 6: Monitor the review report and deficiency letters. For cash requests exceeding 50,000 TL, follow the YMM report, collateral or inspection route; if you have provided collateral, track its release.

None of these steps should be left until the return due date. In an export-intensive business, as the customs declaration matching and the VAT incurred calculation progress during the month, the refund file only needs to be assembled in the filing period.

Until when can you use the refund right?

For exports within the scope of full exemption, the refund request is made by the end of the second calendar year following the period in which the export took place. Within this period, you must both complete the VAT incurred column in the return for the relevant period and submit the petition and documents. For example, for an export whose customs declaration closed in March 2026, the deadline is December 31, 2028.

An exporter who declared the export and left the VAT incurred as “0” may change its mind. In this case, it is sufficient to amend that period’s return and submit the documents before the deadline. For refunds requested with a YMM report, the report must be submitted within six months after the end of this period.

What happens to the refund if exported goods are returned?

Returned goods have different consequences depending on the extent to which the export exemption was used. If no refund was requested or the VAT incurred was recovered through deduction, no further action is needed. If the refund has not yet been made, the amount attributable to the returned goods is deducted on line no. 103 of that period’s return, and no VAT is charged at customs.

If the goods are returned after the refund has been received, the refund amount attributable to the returned portion must be paid at customs; only then is the import exemption applied. You can deduct this VAT paid at customs in the relevant period. Under the export-value-based refund method for manufacturers as well, the refund amount attributable to the returned goods is paid to customs or collateral is provided.

Export file mistakes we often see in practice

The problems we encounter most often in exporters’ refund files stem not from the legislation but from document consistency:

• Declaring the export by invoice date and overlooking the closing date of the customs declaration
• Converting the foreign currency value at the rate on the invoice date instead of the Central Bank buying rate on the closing date
• Issuing the invoice in the name of an intermediary or logistics company in Turkey instead of the buyer abroad
• Not deducting the value of goods purchased under export registration from the export value when calculating the maximum refund amount
• Adding overheads unrelated to exports to the VAT incurred list

Consider a hypothetical example: a textile manufacturer with foreign shareholders in Ankara records the invoice for a shipment loaded on the last day of the month in that month, but the customs declaration closes on the second day of the following month. If the company declares the export in the invoice month, the filing period and the document period do not match and the refund has to wait for an amended return. This scenario was constructed only to illustrate the logic of the process.

Final assessment for exporters

With a properly built file, a VAT refund on exports is a predictable process. The decisive factors are the closing date of the customs declaration, an exact match with the invoice and a well-supported VAT incurred calculation. You can find our guides on other VAT and filing topics on our Tax Legislation knowledge base page. For the official text of the document list and refund limits, the current text of the VAT General Implementation Communiqué issued by the Revenue Administration (GİB) is the reference source.

At Akal CPA, we manage exporters’ refund files from customs declaration matching through the VAT incurred calculation to following up the review report. You can find the scope of our services on our VAT refund services page.