A New Era in Tax Audits: Pre-Audit Preparation File
Introduction
The Presidency of the Tax Inspection Board (“TIP”) of the Ministry of Treasury and Finance, according to its own official guide, has introduced a fundamental change in the tax audit systematics as of 1 August 2026 (Version 1.0) and has made the “Pre-Audit Preparation File” (“PPF”) available for taxpayers’ use. The application envisages the collection, in an electronic environment and in a standardized and modular file structure, of the information and documents to be requested from the taxpayer before the commencement of a tax audit and, in this respect, constitutes one of the most significant procedural changes recently observed in Turkish tax audit practice. This article will first set out the nature and functioning of the PPF application and then assess its relationship with the provisions on repentance, the issues giving rise to uncertainty, and the points to which taxpayers should pay attention during the process.
What is the PPF?
The PPF is a modular platform developed by TIP and adapted to Türkiye’s needs from the OECD’s “Standard Audit File for Tax (SAF-T)” methodology, enabling the information and documents to be requested from the taxpayer subject to an audit to be compiled digitally, in a standardized and systematic manner. The system is operated through the Petition and Information Submission System (“PISS”), and support is provided to the taxpayer or their certified public accountant through screen assistance, user guides and training videos.
According to the official guide published by TIP, the development process of the PPF was initiated within the Board in 2017; in 2019, the “Standard Audit File (SAF-T) v1.0” guide was prepared; as of 2024, with the aim of adopting an architecture that could be more easily understood by taxpayers, the XML format was abandoned and a structure based on Excel-based, user-friendly screens was adopted; in 2025, the Petition and Information Submission System (TIP-PISS) was introduced for this purpose, and finally, as of 1 August 2026 (Version 1.0), the application was officially made available for taxpayers’ use.
With respect to the legal basis of the application, the TIP’s own explanation is significant: TIP has expressly stated that the PPF is an administrative application developed based on international SAF-T practices, and that the basis for the information and documents actually requested from taxpayers within the scope of the file is the general authority of the Tax Administration to request information regulated under Tax Procedural Law No. 213 (“TPL”); and that there is no separate provision of law or regulation specific to the PPF. It is stated that the application will be implemented gradually and will consist of modules that will be continuously developed.
The main objectives of the application are stated as facilitating taxpayers’ preparation processes during tax audits, ensuring that audits are concluded within a shorter period, and strengthening the digital audit infrastructure. It is also stated that the purpose of the application is to increase taxpayers’ voluntary compliance with tax obligations before imposing penalties.
PPF Process and Its Relationship with the Provisions on Repentance
The application commences with the “Pre-Audit Preparation Letter” sent to the taxpayer by the TIP. This letter is electronically signed with the electronic seal of the Ministry of Treasury and Finance and contains explanations regarding the Pre-Audit Preparation File to be prepared, the period for completion of the file, and the access code enabling access to the relevant file in the PISS. The letter specifies the information and documents requested from the taxpayer and the period within which and the format in which such information and documents are to be uploaded to the system through the PISS (mostly in the form of predefined Excel datasets).
As explicitly set out in the TIP’s official guide, the PPF is conducted through two different workflow models:
(i) Pre-Audit Preparation Model: The preparation process is initiated directly by the Presidency of TIP before any tax audit assignment has been created and without being associated with a specific tax inspector. Following the taxpayer’s completion of the file or the expiry of the relevant period, the prepared file is linked to the relevant audit assignment and automatically made available to the tax inspector.
(ii) Audit Process Model: The process begins after a tax audit assignment has already been created and assigned to the relevant inspector; in this model, the preparation letter is sent by the tax inspector personally. As expressly stated by the TIP, in this model, the Pre-Audit Preparation Letter cannot be sent to the taxpayer before the notification of the commencement of the audit; therefore, in this model, the audit process has already commenced as of the date on which the preparation letter is received.
As of the initial implementation, the PPF is conducted through three modules in terms of subject matter: (i) the Use of Fake Documents Module, (ii) the Full Audit Module, and (iii) the Refund Module. TIP has stated that new modules will gradually be added to the system.
The most concrete benefit provided by the system is preventing the same information and documents from being requested repeatedly in different formats and allowing the taxpayer a reasonable period for preparation.
The aspect of the application that requires the greatest attention from a legal perspective is that, solely in the Pre-Audit Preparation Model, the Pre-Audit Preparation Letter does not mean that the tax audit has commenced. Under this model, the preparation and submission of the file, by themselves, do not lead to the conclusion that a tax criticism has been made or that a tax loss exists; the audit legally commences only upon the issuance and service on the taxpayer of the Notice of Commencement of the Audit, issued pursuant to Article 140 of TPL.
The most concrete legal consequence of this distinction arises in terms of the repentance mechanism regulated under Article 371 of the TPL. One of the conditions for benefiting from the provisions on repentance is that the petition must be submitted “before the commencement of any … tax audit”. Since the Pre-Audit Preparation Letter does not constitute the commencement of the audit, it appears to be legally possible, as a rule, for the taxpayer to declare the deficiencies or errors identified at this stage by requesting repentance. Nevertheless, in question 26 of TIP’s guide, it is stated that the provisions on repentance cannot be benefited from with respect to the subject matter of the file, and that a corrective tax return may be submitted. However, the legal basis for this response is open to debate. Indeed, considering the principle of legality of taxation, linking a consequence preventing repentance to an act not specified in the law, in other words, to the sending of the Pre-Audit Preparation Letter, is open to debate. This is because, pursuant to Article 371 of the TPL, the circumstances in which it is not possible to benefit from the provisions on repentance are exhaustively listed in the text of the provision, and the sending of the preparation letter does not correspond exactly to any of these circumstances. Accordingly, the extent to which the TIP’s restriction of the scope of application of the provisions on repentance through an administrative guide is compatible with the principle of legality is a matter that requires further assessment.
Matters to Which Taxpayers Should Pay Attention
The ability of the PPF process to produce favorable results for the taxpayer largely depends on managing the process correctly and in a timely manner. Considering the assessments regarding the application, taxpayers are particularly advised to pay attention to the following matters:
- Time management: Work on the response should be commenced without waiting until the last day, considering the response/upload period specified in the Pre-Audit Preparation Letter.
- Preliminary review of accounting records: Inconsistencies between tax returns and accounting records should be identified before the file is submitted to TIP, as the system is essentially designed to make such discrepancies visible algorithmically.
- Correct matching and explanation: Correctly matching each uploaded document with the relevant transaction and consistently completing the explanation fields will prevent misunderstandings at subsequent stages of the audit.
- Coordination with professional advisers: Close coordination should be maintained with certified public accountants and lawyers; procedural documents such as authorization documents and powers of attorney should not be neglected.
- Decision on timing and process management: The choice among repentance, filing a corrective tax return, or declaring with reservation of rights in respect of identified errors and deficiencies should be determined before the Notice of Commencement of the Audit is served, taking into consideration criteria such as potential penalty risks, ability to pay, willingness to initiate a dispute, and the possibility of benefiting from reduced rates.
- Awareness of the evidentiary nature: The file should be prepared with the awareness that each piece of information and document submitted within the scope of the PPF constitutes evidence that may form the basis of the audit report and, if necessary, a dispute at subsequent stages.
- Potential special irregularity penalty: According to the guide, since the preparation letter is in the nature of an information request letter, failure to respond within the prescribed period or providing incomplete or misleading information may result in the imposition of a special irregularity penalty pursuant to repeated Article 355 of the Tax Procedural Law.
In addition, the TIP’s official statement has confirmed that the basis for the information and documents requested within the scope of the PPF is the general provisions of the TPL concerning requests for information, whereas the PPF itself is based not on a provision of law or regulation, but on an administrative arrangement based on international SAF-T practices. Within this framework, the question of whether the specific limits of the information and documents that may be requested from taxpayers will be determined by the general framework of the TPL’s provisions on requests for information or by the TIP’s module-specific guides, as well as when the system will be subject to a separate regulation at the level of law or regulation, remains an issue to be monitored.
Conclusion
The Pre-Audit Preparation File application represents an important step towards digitalization and standardization in tax audits. When managed correctly and in a timely manner, the system provides the taxpayer with greater predictability over the process, sufficient time for preparation, and the opportunity to remedy errors and deficiencies before the official audit commences. Nevertheless, concretizing the legal basis of the application at the level of law/regulation, setting out the commencement of the audit and the limits of the application of the provisions on repentance in a manner that leaves no room for doubt, and preserving procedural safeguards concerning taxpayer rights are important for the sound functioning of the application. Taxpayers and certified public accountants are advised to manage the process with legal professional support from the moment they receive the Pre-Audit Preparation Letter and by taking the above-mentioned matters into consideration, to minimize potential risks.
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