A person or company earning income from abroad presents the tax authority of the other country with proof of being a taxpayer in Türkiye in order to benefit from a double taxation agreement: the tax residence certificate (mukimlik belgesi). For companies a tax plate (vergi levhası) or a letter confirming taxpayer registration is sometimes asked for as well. The apostille route for these documents turns on two questions: is the document administrative, and does it fall under the commercial exclusion of the Convention. This page sets out both questions as they stand, including the part that could not be verified.
Tax residence certificate against the residence certificate
Circular no. 3 on double taxation agreements of Gelir İdaresi Başkanlığı (GİB), the Turkish Revenue Administration, names the offices that issue the tax residence certificate: the Large Taxpayers Tax Office Directorate for its own taxpayers, the tax office directorates (vergi dairesi başkanlıkları) of Ankara, Antalya, Bursa, İstanbul, İzmir, Kocaeli and Trabzon, and GİB itself, through its European Union and Foreign Relations Department, for foreign nationals, for certificates meant for Austria, Switzerland and Saudi Arabia, and for persons outside the first two groups. A local tax office is not on that list. The circular has the certificate drawn up in three copies, with country forms for some agreements, a Greek-language form for Greece among them; e-Devlet carries a GİB application petition for it. The certificate shows that a person or company is treated as resident in Türkiye for tax purposes in a given year, so that the relevant agreement can be applied. The residence certificate issued by the civil registry office shows only an address. When a foreign institution writes “residence” without saying which document it means, the two are not presented in each other’s place; the civil registry document has its own page on this site.
Does the commercial exclusion of article 1 apply
The first article of the Convention excludes administrative documents dealing directly with commercial or customs operations. A tax residence certificate is not a customs or shipping document; it is issued so that a tax agreement can be applied, and it describes the taxpayer’s status rather than any single commercial transaction. Strong as that reading is, this site’s survey found no official page stating how the Turkish apostille authorities classify the tax residence certificate or the tax plate under this exclusion. The general rule of the Onikişubat District Governor’s Office points the way: a document’s commercial content, or the fact that it belongs to a company, does not by itself mean that no apostille can be issued; what is excluded is an administrative document tied directly to a commercial or customs operation.
Tax plate and tax residence certificate on different roads
The tax plate shows the taxpayer registration and the previous year’s tax base; why a foreign institution asks for it, and in which form, is for that institution to say. If it is presented as a barcode printout, the provincial and district governor’s offices do not place a paper apostille on it, so the issuing office’s handwritten certification is needed first. The tax residence certificate, when drawn up by one of the directorates named above with a signature and seal, can go straight to the apostille counter as an administrative document. Since the two documents answer different questions, the receiving institution should say from the outset which one it wants.
The French table and a document tied to a commercial operation
In the legalisation table of the French Ministry for Europe and Foreign Affairs, the administrative documents column of the row for Türkiye refers to footnote (9): legalisation for a document issued by an administration and tied directly to a commercial or customs operation, exemption for civil status documents, apostille for everything else. The table does not say where a Turkish tax residence certificate presented to the French tax administration falls among the three; unless the document is seen as tied directly to a commercial operation, the apostille column is expected. That is an interpretation, and the practice of the French administration was not verified on this site.
e-Apostil and barcode tax documents
e-Apostil, the official Turkish electronic apostille system, accepts no applications for tax documents; its list is limited to the criminal record extract, court judgments, the civil registry extract and the multilingual civil status extracts. The same system’s FAQ adds that no e-apostille is issued for certain international shipping documents and invoices, which shows that the commercial exclusion of the Convention operates on the electronic route too. For a tax document the only route is paper: a hand-signed copy and an apostille at a provincial or district governor’s office.
Treaty terms in the tax certificate translation
Whether a translation link opens at all depends on the language in which the certificate was issued and on what the receiving tax authority asks for. If it was issued in Turkish, the translation is made from the apostilled copy, and the translator carries over the name of the agreement and the article number exactly as printed; the equivalent of “mukim” is the term used in the official text of the agreement concerned. The translation is certified by a notary (the translator being a yeminli tercüman, a sworn translator whose oath is recorded there), and whether that certification needs its own apostille is decided by the tax authority of the receiving country.