Delivery Note in Turkey is a mandatory commercial document regulated under Articles 230 and 231 of the Turkish Tax Procedure Law (VUK). The document evidences the physical movement of goods and constitutes a critical control point within Turkey’s tax audit framework.Failure to comply with statutory issuance requirements may trigger special irregularity penalties under Article 353 of the VUK, potential tax base reassessment, and secondary financial exposure.
Legal Framework
The obligation to issue delivery notes in Turkey is regulated primarily under:
- Tax Procedure Law (VUK) Articles 229–231
- Article 230 VUK (mandatory content requirements)
- Article 353 VUK (special irregularity penalties)
- Turkish Commercial Code (TTK) Article 21
- E-Delivery Note General Communiqué No. 509 (Official Gazette dated 19 October 2019, No. 30923)
as amended by subsequent communiqués.
For official guidance, technical specifications, and current implementation updates, refer to the Turkish Revenue Administration (GİB).
Under Article 230/5 of VUK, goods cannot be transported without a duly issued delivery note. The obligation arises at the moment of dispatch. The delivery note is not a commercial preference; it is a statutory tax document. Failure to comply triggers administrative penalties and potential tax exposure.
1. Definition and Legal Nature of a Delivery Note
A delivery note (Sevk İrsaliyesi) is a mandatory tax document evidencing the physical movement of goods.
It confirms:
- Identity of sender and recipient
- Description and quantity of goods
- Date of dispatch
- Place of dispatch and destination
- Vehicle and transporter information (where applicable)
The document must be issued before goods leave the warehouse or place of business.
Under Article 230 VUK, the delivery note must accompany the goods during transport and be presented upon request during tax inspections or roadside controls.
2. Timing of Issuance
The delivery note must be issued:
- At the moment of dispatch, and
- Before physical shipment begins.
Subsequent issuance is not compliant.
Issuing a delivery note after dispatch constitutes a formal violation and may result in penalties under Article 353 VUK.
3. Types of Delivery Notes Under Turkish Practice
Although the VUK does not formally categorize delivery notes into types, commercial practice recognizes the following operational forms:
a) Dispatch Delivery Note
Issued when goods are sold and physically delivered.
Mandatory at time of shipment.
b) Return Delivery Note
Issued when goods are returned due to defect, cancellation, or contractual non-performance.
Essential for inventory reconciliation and VAT adjustments.
c) Transfer Delivery Note
Issued for inter-warehouse or inter-branch transfers within the same company.
Required even where ownership does not change.
d) Consignment Delivery Note
Issued where goods are sent for sale without immediate transfer of ownership.
Taxable event occurs only upon sale; however, shipment still requires a delivery note.
4. Difference Between Invoice and Delivery Note
Under Article 231 VUK:
- An invoice must be issued within 7 days following delivery.
- Delivery note documents shipment.
- Invoice documents sale and tax liability.
Where invoice is issued at the time of dispatch, a “Delivery-Integrated Invoice” may be used.
Failure to issue invoice within the 7-day period may trigger irregularity penalties and VAT timing risks.
5. E-Delivery Note (e-İrsaliye) System
The e-Delivery Note system was introduced under General Communiqué No. 509.
It entered into force in stages beginning in 2018 and has been expanded through amendments.
An e-Delivery Note has the same legal validity as a paper delivery note.
Mandatory Transition Threshold
As of the current regulatory framework:
Taxpayers with annual gross sales revenue exceeding the threshold determined by the Revenue Administration (currently 10 million TRY under the most recent amendments) are required to transition to the e-Delivery Note system.
Entities already obligated to use e-Invoice are generally subject to corresponding e-Delivery Note obligations, subject to sector-specific rules.
Transition timelines are determined by the Communiqué and subsequent amendments. Failure to transition within the prescribed period results in penalties under Article 353 VUK.
6. Mandatory Content Requirements
Under Article 230 VUK, a delivery note must include:
- Serial and sequence number
- Issue date
- Sender’s and recipient’s trade name, address, and tax number
- Quantity and type of goods
- Transport details
- Signature (for paper notes) or electronic approval (for e-Delivery Notes)
Missing mandatory information may invalidate the document and expose the taxpayer to penalties.
7. Retention and Archiving Obligations
Under Article 253 VUK:
- Delivery notes must be retained for a minimum of five years.
- E-Delivery Notes must be stored electronically in compliance with Revenue Administration standards.
Failure to retain documentation may result in:
- Evidentiary weakness during tax audits
- Rejection of expense deductibility
- VAT input denial
- Special irregularity penalties
8. Penalties and Risk Exposure
Non-compliance may result in:
- Special irregularity penalties under Article 353 VUK
- Rejection of expense or cost deduction
- VAT assessment adjustments
- Inventory mismatch assessments
- Tax loss penalty (vergi ziyaı cezası) where understatement occurs
- Late payment interest
Transporting goods without a delivery note may also result in roadside inspection penalties and seizure risks in certain cases.
From an audit perspective, delivery note compliance is frequently reviewed in:
- Transfer pricing examinations
- Inventory reconciliation audits
- VAT refund inspections
- Sectoral compliance reviews
9. Operational and Financial Impact
Improper delivery note management may affect:
- Inventory accuracy
- Revenue recognition timing
- VAT calculation
- Audit defensibility
- Working capital reporting
- ERP data integrity
For large-scale operations, inconsistent dispatch documentation may create systemic tax exposure. CFOs and financial controllers should ensure:
- ERP-integrated issuance
- Real-time dispatch validation
- Automated e-Delivery Note controls
- Periodic compliance testing
Compliance Perspective
Delivery note management is not merely a documentation process. It is a core tax compliance mechanism directly linked to revenue recognition, VAT timing, and audit defensibility.
Companies operating in Turkey should implement structured internal controls to mitigate dispatch-related tax exposure.
For a technical compliance assessment, e-Delivery Note transition analysis, or risk evaluation under VUK Articles 230–231 and Communiqué No. 509, professional advisory support should be obtained prior to system implementation or audit review.
