Liability Arising from Trust in Corporate Law

31.03.2026 Prof. Dr. H. Ercüment Erdem

Introduction

With the proliferation of group of companies’ structures, the need to protect the trust placed in the reputation of the group has gained importance. Article 209 of the Turkish Commercial Code ("TCC") regulates the liability of the parent company arising from the trust created in third parties using the group's reputation. This study examines the theoretical foundations of the said provision, its conditions of application, and its practical manifestations considering judicial decisions.

Article 209 of the TCC, titled "Liability arising from trust," reads as follows: "The parent company shall be liable for the trust created by the use of the group's reputation in cases where such reputation has reached a level that inspires confidence in the public or consumers.

The provision exclusively regulates the liability arising from the use of trust placed in the reputation of a group of companies and constitutes a specific manifestation of the general doctrine of liability arising from trust. It derives from this general doctrine and from the concept of "Konzern trust liability" as crystallised in the Swiss Federal Court's Wibru/Swissair decision[1]

The fundamental condition of liability is the element of "use of reputation". Whether the reputation has been used is determined according to the circumstances of each case[2].  It is not strictly necessary that the name be expressly stated or that the group logo be visibly displayed for such use to be established[3]

For trust liability to arise, the parent company must have engaged in conduct particularly apt to inspire trust, the counterparty must have relied on the trust so created, the trust must be worthy of protection, and the trusting party must have made a disposition in reliance on that trust[4]

The legal nature of liability arising from trust is debated in the doctrine. According to one view, it may be assessed within the scope of tort liability[5]; Tekinalp characterises it as "culpa in contrahendo[6] liability. According to another view, trust liability is not a "tort-like" or "contract-like" liability in the sense of the older dogmatic approach, but rather a sui generis statutory obligation[7].  Given that the legislator has regulated this liability through a specific provision, the view that trust liability constitutes a sui generis statutory obligation should be given precedence.

Liability Arising from Trust in Corporate Law
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Conditions of Liability Pursuant to Article 209 of the TCC

Existence of a Group of Companies within the Meaning of the Turkish Commercial Code

To invoke the parent company's liability arising from trust, the existence of a group of companies within the context of the TCC is required. Under Turkish law, a group of companies arises where a commercial company comes under the dominance of another commercial company or enterprise that is legally independent from it.

The elements of dominance are regulated under Article 195 et seq. of the TCC. Circumstances such as the parent company holding the majority of voting rights in the subsidiary, having a say in its management, the existence of a dominance agreement, or exercising de facto control over the subsidiary indicate the existence of a group of companies. Since the legislator has deliberately confined the scope of the provision to groups of companies, Article 209 of the TCC does not apply in the absence of a group of companies within the meaning of Article 195 of the TCC.

In the context of Article 209 of the TCC, the addressee is the parent company that centralises the group's reputation within itself. Pursuant to Article 195 of the TCC, the provisions on groups of companies apply where the registered office of either the parent company or at least one of the subsidiaries is in Türkiye.

The Group's Reputation Reaching a Level That Inspires Confidence

For Article 209 of the TCC to apply, the group of companies must possess a certain reputation, and this reputation must have reached a level that inspires confidence in the public or consumers. The trust deemed worthy of legal protection is not the abstract inner confidence that the public feels towards reputable groups, but rather the concrete trust that the parent company creates in the counterparty through its own conduct within a specific business context[8].

The explanatory memorandum to Article 209 of the TCC states that not every group of companies falls within the scope of the provision and that the group's reputation must have reached a level that inspires confidence. The wording of the provision emphasises a widespread reputation rather than a merely local one.

To speak of liability, the parent company must inspire a high degree of trust through its own conduct within a specific business context and must cause damage to the counterparty by frustrating that trust in a manner contrary to good faith. The mere fact that the group constitutes a quality symbol is not taken as the basis for liability as an abstract form of trust[9].

In the doctrine, Battal determines the existence of reputation by criteria such as the parent company having an easily memorable name or brand, and the public or consumers turning to the subsidiary in reliance on the group's name. The 22nd Civil Chamber of the Ankara Regional Court of Appeal adopts the same view and states that where the group conducts its activities under a common brand name, persons in the vicinity would assume that they are dealing with one of several enterprises operating under a single umbrella[10].

Use of the Confidence-Inspiring Reputation in a Specific Transaction

For liability to arise under Article 209 of the TCC, it is not sufficient for the group of companies merely to possess a reputation that has reached a confidence-inspiring level. This reputation must have been used in the context of a specific legal transaction or a particular business dealing.

The central condition of liability is the use of reputation. In the absence of such use, mere membership in the group does not give rise to liability. Expressions relating to affiliation such as "a company of X / a subsidiary of X" or the use of the group logo alone are not sufficient. Whether the reputation has been used is determined on a case-by-case basis; where the disclosed tables, information, and quality do not correspond to the trust created, the parent company that has not objected to the use of its name shall be held liable for the resulting damage.

The use of reputation is a fact that inspires trust in the third party regarding the specific situation and influences their actions. This may occur through the parent company's own conduct, as well as through statements made by the subsidiary with the knowledge and approval of the parent company.

The 21st Civil Chamber of the Court of Cassation states that for Article 209 of the TCC to apply, the subsidiary's liability must be contractual in nature and that the parent company cannot be held separately liable in cases of tort liability[11]. This approach is sound, as the use of reputation must result in the formation of a legal act or transaction. Since liability arising from trust is a fault-based liability, the parent company must have known or should have been able to know that a concrete expectation was being created in the counterparty.

In a 2020 decision, the 11th Civil Chamber of the Court of Cassation requires, for a concrete expectation to arise, that the parent company or the group has provided the injured party with an oral or written assurance, a letter of credit or similar support, or a declaration in public announcements and advertisements indicating that the subsidiary is backed by the group[12]. The Chamber emphasises that it must be proven that the group's reputation was used in a manner that creates a concrete expectation on the basis of a specific transaction.

The 22nd Civil Chamber of the Ankara[13] Regional Court of Appeal states that the confidence-inspiring reputation must have been used in a specific or determinable field. The court concluded that the conditions of Article 209 of the TCC were not met in the case at hand, on the ground that there was no evidence that the parent company had provided the plaintiff with any oral or written assurance.

Fault and Damage

For the parent company's liability to arise, it must be at fault. Fault may take the form of intent, as well as negligence manifested by remaining silent in the face of the subsidiary's use of reputational elements. Even slight negligence may constitute fault, and under the contractual liability regime, the burden of proving absence of fault rests on the parent company. The İzmir 3rd Commercial Court of First Instance also expressly stated in its 2021 decision that this liability is a fault-based liability[14].

The other element required alongside fault is damage. Liability arises where the concrete and justified trust that the party in a legal relationship with the subsidiary has placed in the group has been frustrated and has caused damage. The scope of damage consists of the difference between the state in which the assets would have been had the breach of trust not occurred and their current state.

Applicability to Merchants

Whether the trust that merchants, who are subject to the duty of prudent conduct pursuant to Article 18/2 of the TCC, place in a group of companies can be protected under Article 209 of the TCC is assessed separately. Consumers are the group that can benefit most broadly from Article 209 of the TCC; [15]merchants, who are expected to safeguard their own interests with due care by virtue of the duty of prudent conduct, may only fall within the protective scope of the provision under stricter conditions. Indeed, the 22nd Civil Chamber of the Ankara Regional Court of Appeal confirmed this point in its 2021 decision[16].

Conclusion

Article 209 of the TCC is a specific manifestation of liability arising from trust, particular to groups of companies. The provision constitutes a sui generis statutory obligation. Its application requires, first and foremost, the existence of a group of companies within the meaning of Article 195 of the TCC. In the absence of a group relationship, the provision does not apply. It is further required that the group's reputation has reached a level that inspires confidence in the public or consumers. This trust is not an abstract perception of quality. It is the justified expectation that the parent company creates in the counterparty through its concrete conduct.

The central condition of liability is that the reputation has been used in the context of a specific legal transaction or business dealing. The mere indication of group affiliation is not deemed sufficient on its own. In addition, the parent company must be at fault. It is also required that the counterparty has suffered damage because of the frustration of trust.

As regards merchants, the conditions for falling within the protective scope of the provision are held to stricter standards by virtue of the duty of prudent conduct.

In conclusion, Article 209 of the TCC provides an important safeguard for the protection of third parties' trust in the group. However, the emergence of liability is subject to strict conditions. Judicial decisions also demonstrate that these conditions must be rigorously examined.

References
  • Turkish Commercial Code Art. 209 Justification.
  • Turkish Commercial Code Art. 209 Justification.
  • Ahmet Battal, “Şirketler Topluluğunda Güvenden Doğan Sorumluluk”, Marmara Üniversitesi Hukuk Fakültesi Hukuk Araştırmaları Dergisi, 2012, T. 18, V. 2, p. 245 – 254, p. 251; Abuzer Kendigelen, Türk Ticaret Kanunu Değişiklikler, Yenilikler ve İlk Tespitler, İstanbul, On İki Levha, 2011, p. 163.
  • Gül Okutan Nilsson, Türk Ticaret Kanunu Tasarısı’na Göre Şirketler Topluluğu Hukuku, İstanbul, On İki Levha, 2009, p. 488; Asuman Yılmaz, Türk, İsviçre ve Alman Hukuklarında Şirketler Topluluğuna Güvenden Doğan Sorumluluk, İstanbul, On İki Levha, 2010, p. 298-299.
  • Efe Dündar, Yeni Türk Ticaret Kanunu Çerçevesinde Çok Uluslu Şirketler, Doktora Tezi, İstanbul Kültür Üniversitesi Sosyal Bilimler Enstitüsü, 2013, p. 204.
  • Reha Poroy / Ünal Tekinalp / Ersin Çamoğlu, Ortaklıklar Hukuku II, 14. Bası, İstanbul, Vedat, 2019, p. 795.
  • Hasan Pulaşlı, “Türk Ticaret Kanunu Tasarısına Göre Şirketler Topluluğunun Temel Nitelikleri ve Hâkim Şirketin Güven Sorumluluğu”, Gazi Üniversitesi Hukuk Fakültesi Dergisi, 2007, T. 11, V. 1-2, p. 259 – 277, p. 269; Baran Ulaş, Sermaye Şirketlerinde Sınırlı Sorumluluk İlkesinin İstisnası Olarak Tüzel Kişilik Perdesinin Kaldırılması, Ankara, Seçkin, 2020, p. 159.
  • Tekinalp, p. 600, para. 23-158; Poroy/Tekinalp/Çamoğlu, p. 814.
  • Başak Şit İmamoğlu, Planlı Eskitme, Ankara, Banka ve Ticaret Hukuku Araştırma Enstitüsü, 2020, p. 339.
  • Battal, p. 250.
  • Court of Cassation 21st Civil Chamber, 2017/4601 File, 2017/7189 Decision, dated 3.10.2017; Court of Cassation 21st Civil Chamber, 2018/59 File, 2018/458 Decision, dated 23.1.2018; Court of Cassation 21st Civil Chamber, 2018/1430 File, 2018/3811 Decision, dated 16.4.2018.
  • Court of Cassation 11th Civil Chamber, 2019/4830 File, 2020/4201 Decision, dated 19.10.2020.
  • Ankara Regional Court of Appeal 22nd Civil Chamber, 2018/2489 File, 2021/1119 Decision, dated 24.6.2021.
  • İzmir 3rd Commercial Court of First Instance, 2017/189 File, 2021/301 Decision, dated 26.3.2021.
  • Battal, p. 252.
  • Ankara Regional Court of Appeal 22nd Civil Chamber, 2018/2489 File, 2021/1119 Decision, dated 24.6.2021.

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An Update from the ICC: The ICC Force Majeure and Hardship Clauses 2020
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The Carrier’s Right of Retention on Goods
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Legal Liability of Limited Company Managers
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Legal Liability of Limited Company Managers
Commercial Law January 2020
Shareholders’ Agreements in Family Businesses
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Employer’s Remedies under FIDIC Silver Book
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Employer’s Remedies under FIDIC Silver Book
Commercial Law October 2019
Postponement of General Assembly Meetings in Joint Stock Companies
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Wholesale of a Significant Amount of Company Asset
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Restructuring of Debts Owed to the Financial Sector
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Revision to International Commercial Terms: Incoterms® 2020
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Revision to International Commercial Terms: Incoterms® 2020

INCOTERMS are a set of rules introduced by the International Chamber of Commerce (ICC) to explain the commercial terms that are widely used in international trade. The purpose of the Incoterms rules is to contribute to and facilitate the safe and swift conduct of international trade...

Commercial Law September 2019
Transfer of Employee Rights and Claims in Company Spin-offs
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The Relation between Contract of Carriage by Sea and Bill of Lading
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Transfer of Seized Shares
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Transfer of Seized Shares
Commercial Law July 2019
Privilege to be represented on the Board of Directors
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Lack of Mandatory Bodies in Joint Stock Companies
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Corporatization of Football Clubs
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Corporatization of Football Clubs
Commercial Law April 2019
Secondary Liability of Companies Participating to Spin-off
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2016 York Antwerp Rules
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2016 York Antwerp Rules
Commercial Law March 2019
Prohibition of Joint Stock Companies’ Subscription for their own Shares
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Amendments on Capital Loss and Insolvency
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Amendments on Capital Loss and Insolvency
Commercial Law September 2018
Foreign Currency Payment Ban
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Foreign Currency Payment Ban
Commercial Law September 2018
Premium Capital Increase in Joint Stock Companies
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Installment Sales Agreements
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Installment Sales Agreements
Commercial Law July 2018
Usufruct Right on Joint Stock Company’s Registered Shares
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Share Pledges in Limited Liability Companies
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Arrest of Ships under Turkish Law
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Arrest of Ships under Turkish Law
Commercial Law May 2018
Share Pledges in Joint Stock Companies
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Share Pledges in Joint Stock Companies
Commercial Law May 2018
Trust Liability in terms of Groups of Companies
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Updated FIDIC Contracts
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Updated FIDIC Contracts
Commercial Law April 2018
The Consequences of Late Payment in the Procurement of Goods and Services
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The Regulation on Application of Industry Cooperation Projects
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Liability of the Sea Carrier for the Carriage of Goods under Turkish Law
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Features of Joint Venture Contract
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Features of Joint Venture Contract
Commercial Law October 2017
Capital Increase through Internal Resources in Joint Stock Companies
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Stock Option Plans in Turkey
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Stock Option Plans in Turkey
Commercial Law June 2017
Voting Agreements under Turkish Law
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Voting Agreements under Turkish Law
Commercial Law May 2017
Importance of ICC Model Contracts as Part of Soft Law
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Pre-emptive Right in Joint Stock Companies
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Pre-emptive Right in Joint Stock Companies
Commercial Law April 2017
Holding Company Structure under Turkish Law
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Holding Company Structure under Turkish Law
Commercial Law January 2017
European Commission Preliminary Report on the E-commerce Sector Inquiry
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Important Principles regarding Dividends in Joint Stock Companies
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Healthcare PPP Projects: Funders’ Direct Agreements
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Latest Amendments to the Turkish Commercial Code and the Law on Cheques
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Indemnity Clauses Under Share Purchase Agreements
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Loss Of Capital in Joint Stock Companies
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Loss Of Capital in Joint Stock Companies
Commercial Law September 2015
Ceasing Commercial Activities versus Liquidation of Legal Entities
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Termination Agreements For Agency And Distribution Contracts
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Draft Bill On Swiss Corporate Law Reform
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Leveraged Buyouts Within The Context Of Financial Assistance Ban
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Joint Stock Companies’ Capacity Of Becoming A Surety
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Provisions Introduced By The Law On The Regulation Of Electronic Commerce
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Non-Compete Obligation Of The Commercial Agent
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Non-Compete Obligation Of The Commercial Agent
Commercial Law December 2014
Right To Request Special Audit
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Right To Request Special Audit
Commercial Law October 2014
Special Committee Of Preference Shareholders
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Special Committee Of Preference Shareholders
Commercial Law October 2014
Amendments To The Turkish Commercial Code By Omnibus Law No. 6552
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Termination Of A Limited Liability Company By Just Cause
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Capital Increase Through Capital Subscription
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Capital Reduction Within The Scope Of The Turkish Commercial Code
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Delegation Of Duties Of The Board Of Directors
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Duties, Obligations And Liabilities Of Liquidators
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Conditional Capital Increase
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Conditional Capital Increase
Commercial Law March 2014
Termination Of A Joint Stock Company By Just Cause
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General Communique On Electronic Books
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General Communique On Electronic Books
Commercial Law December 2013
Domination Agreements
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Domination Agreements
Commercial Law January 2014
The Contribution Of Receivables As Capital in Commercial Companies
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Representation in Joint Stock Companies
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Representation in Joint Stock Companies
Commercial Law December 2013
Squeeze-Out in Group Companies
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Squeeze-Out in Group Companies
Commercial Law November 2013
Shareholder Agreements
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Shareholder Agreements
Commercial Law November 2013
The Regulation On Private Health Insurance
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The Regulation On Private Health Insurance
Commercial Law October 2013
Ship Mortgages Under The Commercial Enterprise Pledge
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New Lawsuits Regarding Mergers, Spin-Offs And Conversions
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Freedom of Settlement of Foreign Companies
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Freedom of Settlement of Foreign Companies
Commercial Law September 2013
Branches And Liaison Offices
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Branches And Liaison Offices
Commercial Law August 2013
Preliminary Companies Pursuant to Provisions of the TTC
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Exit Right And Squeeze Out From Limited Liability Companies
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Independent Audit of Joint Stock Companies According to The TCC No. 6102
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Establishment Of A Limited Liability Company Under Law No. 6102
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Conversion of the Commercial Enterprise
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Conversion of the Commercial Enterprise
Commercial Law April 2013
Squeeze-Out, Sell-Out And Exit Rights in Joint Stock Companies
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Trade Registry Regulation
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Trade Registry Regulation
Commercial Law January 2013
Law Numbered 6361 On Financial Leasing, Factoring And Financing Companies
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Financial Leasing Agreements
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Financial Leasing Agreements
Commercial Law December 2012
Jouissance Shares For The Founders in The Turkish Commercial Code
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Agency Contracts Under Turkish Law And Newly Regulated Matters
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Advance Dividend
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Advance Dividend
Commercial Law September 2012
Cumulative Voting in Non-Public Joint Stock Companies
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Amendments Made in the New TCC with the Law No. 6335
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Dissolution And Liquidation Of Joint Stock Companies
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Limited Corporations Under Turkish Commercial Code Numbered 6102
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The Prohibition Against Financial Assistance under the New TCC
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Share Buyback of Companies Pursuant to the New TCC
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Innovations in The New Turkish Commercial Code Concerning Voting Rights
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Services Provided by Coastal Facilities and Applicable Tariffs
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