As of the 2025 fiscal year, certain exemptions and deductions declared in the corporate income tax return are subject to mandatory certification by a Sworn-in Certified Public Accountant (CPA). This regulation constitutes a significant compliance and risk management issue, particularly for companies benefiting from high-value tax incentives.
Below is a systematic overview of the main triggering conditions, monetary thresholds, and special cases.
1. Monetary Thresholds Triggering CPA Certification
1.1. TRY 500,000 Threshold for a Single Exemption or Deduction
If any single exemption or deduction item declared in the corporate tax return exceeds TRY 500,000, a CPA certification report becomes mandatory for that item.
This threshold is evaluated separately for each line item in the return.
1.2. Total of Multiple Exemptions and Deductions Exceeding TRY 1,000,000
If the total amount of multiple exemptions and deductions declared in the return exceeds TRY 1,000,000, certification is required.
Importantly:
- Even if each individual item is below TRY 500,000,
- Certification is still required if the aggregate total exceeds TRY 1,000,000.
1.3. “Other Deductions” Line Exceeding TRY 1,000,000
If the total amount reported under the “Other Deductions” line exceeds TRY 1,000,000, YMM certification is mandatory.
This includes items classified under “Other Deductions and Exemptions” in the corporate tax return.
1.4. Tax Advantage from Rate-Based Incentives Exceeding TRY 200,000
If an exemption or deduction provides a tax benefit due to a preferential rate application and the resulting tax advantage exceeds TRY 200,000, certification is required.
The relevant threshold applies to the tax saving effect, not to the deductible base amount.
2. Cases Requiring Certification Regardless of Amount
Certain exemptions and deductions require CPA certification regardless of monetary thresholds.
Examples include:
- Investment incentives under Article 32/A of the Corporate Tax Law
- Specific deductions under Article 10 of the Corporate Tax Law
In such cases, certification is mandatory irrespective of the amount involved.
3. Entities Outside the Scope
The following entities are exempt from the CPA certification requirement:
- State Economic Enterprises (SOEs)
- Entities affiliated with SOEs
For these entities, the certification obligation does not apply.
4. Annual Adjustment of Monetary Thresholds
The specified monetary thresholds are increased annually by half of the official revaluation rate.
Therefore, companies must review updated limits each fiscal year before filing their returns.
5. Practical Considerations
5.1. Applying Deductions Without Certification
If certification is required but not obtained:
- The relevant exemption or deduction may be denied,
- Tax loss penalties may arise,
- Late payment interest may be imposed.
5.2. Risk Management Perspective
Early planning of the certification process is particularly important in cases involving:
- Large-scale investment incentives
- R&D and design deductions
- Foreign income exemptions
- High-value donations and sponsorship deductions
- Complex tax base structures within group companies
A CPA certification report is not merely a procedural formality; it functions as a tax risk control mechanism.
6. Strategic Considerations
The certification requirement reflects the tax administration’s policy of increasing oversight over high-value tax advantages.
Accordingly, companies should:
- Monitor deduction amounts throughout the year,
- Analyze in advance whether thresholds may be exceeded,
- Plan the certification process before filing the corporate tax return.
The CPA certification process is not limited to checking monetary thresholds. The legal basis of the deduction, calculation methodology, supporting documentation, and accounting treatment must be evaluated collectively.
At ÖzbekCPA, we provide comprehensive support in:
- Pre-review of corporate income tax returns,
- Certification requirement analysis,
- Coordination with sworn-in CPAs (YMMs),
- Risk simulations and alternative scenario assessments.
For a detailed evaluation tailored to your company, please feel free to contact us.
