Paying a foreign advertising platform or a foreign publisher from Turkey can raise two separate tax questions, one under the VAT Law and one under the Digital Services Tax Law. The two statutes cover different subjects, and neither replaces the other. Who bears which obligation depends on your business and on the service, so the useful output is a clear set of questions and records, not a verdict. This is not legal advice.
A SaaS invoicing startup that buys search ads, a creator who places sponsored posts on foreign sites, and a procurement lead who pays for an agency's media all meet the same documents.
The foreign invoice from the buyer's seat
An invoice from a foreign supplier is prepared under the supplier's home practice, so it can look unlike a Turkish invoice. The first thing to read is which company issued it, from which country, and to whom.
Table: what to check on a foreign service invoice.
| Field | Why it matters |
|---|---|
| Issuing company and country | Shows whether the supplier sits outside Turkey |
| Billed party | Is it your company name or an agency's name? |
| Service description | Advertising, publishing, measurement tool or something else |
| Tax line | Is a tax shown, and what does the platform say it is? |
| Currency and payment date | Carried into accounting records |
The tax line deserves care. If a tax appears on the invoice, the document itself may not tell you which tax it reflects. The platform's billing help page can say what the line is.
When there is only a statement
If spend appears as a statement entry rather than an invoice, download it, match it with the bank or card record and send it to accounting. Whether a statement is accepted as a document is a point to settle in your own records.
Two taxes, two statutes, two questions
Short version: the VAT Law asks whether the service is an import of services or another taxable transaction and who answers for the tax. Law 7194 asks whether the service is one of the listed digital services provided in Turkey and who the taxpayer is. Keep the two apart in your notes, because one invoice can raise both.
Table: the two taxes side by side.
| Point | VAT Law (3065) | Law 7194 |
|---|---|---|
| Subject | Transactions listed in article 1, including imports of goods and services | Revenue from listed digital services provided in Turkey |
| Wording to watch | "Every kind of goods and services import" | "Advertising services provided in a digital environment" |
| Taxpayer in the statute | Article 8(1): those who supply goods and perform services; in imports, those who import goods and services | Digital service providers |
What the VAT Law says about imports
Article 1 of the VAT Law (Opens in a new tab) states that transactions carried out in Turkey are subject to VAT and lists them. The list includes deliveries and services within commercial, industrial, agricultural and self-employed activity, and "every kind of goods and services import". A foreign advertising or publishing service may raise the import wording. Whether a given service counts as an import cannot be read from that line alone, and the documentation has no statement on it.
The article goes on to say that the legal status, nationality, residence or place of business in Turkey of those carrying out the commercial, industrial, agricultural and self-employed activities does not change the nature of the transactions or prevent taxation. That sentence concerns those listed activities. How it applies to a foreign ad platform's service is something the documentation does not state.
Article 1(2) and article 8(1)(b) read together
Article 1 of the VAT Law lists, among the transactions in Turkey that are subject to VAT, in its second item "every kind of goods and services import". The first paragraph of article 8 names the VAT taxpayers: under (a), those who supply goods and perform services, and under (b), in imports, those who import goods and services. Read side by side, the two provisions say that in an import the taxpayer named is the person who imports the service. Who that is in a given foreign invoice cannot be read from the text, and no ruling on liability is made here.
Practical suggestion: split your invoice into two columns, one for the party providing the service and one for the party receiving it, and mark in your own notes which of the two provisions each line touches. The documentation has no statement on whether an advertising service counts as an import.
Article 9 and who answers for the tax
Article 9, paragraph 1, lets the Ministry of Finance hold the parties to taxable transactions liable for payment of the tax, where the taxpayer has no residence, workplace, legal seat or business centre in Turkey and in other cases deemed necessary, in order to secure the tax claim. It is a power, described in general terms. Who is held liable in a given foreign service purchase is not answered by the paragraph alone.
The paragraph adds a sentence on services provided electronically to individuals who are not VAT taxpayers by providers with no residence, workplace, legal seat or business centre in Turkey: the VAT on those is declared and paid by the providers. That sentence is about individuals who are not VAT taxpayers. If your business is a VAT taxpayer, it does not describe your position directly.
Ministry rules for electronic services
The paragraph also says the Ministry is authorised to set the scope of electronically provided services and the procedures for applying the rules. The statute sets the frame and the detail sits in separate regulations.
Services bought without a document
Paragraph 2 deals with services bought without a document: where such a purchase is established, the VAT lost is claimed from the taxpayer who bought the service. For foreign spend this makes the paper trail a priority. Whether a platform statement counts as a document is again a point to settle in your own records.
What Law 7194 taxes
Article 1 of Law 7194 (Opens in a new tab) subjects the revenue from certain services provided in Turkey to the digital services tax. The groups it lists are:
- advertising services of every kind provided in a digital environment, including advertising control and performance measurement services, transmission and management of user data and technical services relating to delivering the advertisement
- the sale of audio, visual or digital content in a digital environment, and digital services that allow listening, watching, playing, saving or using such content
- providing and operating digital environments in which users can interact, including services that support the sale of goods or services between users
The second paragraph of article 1 extends the tax to revenue from intermediary services that digital service providers give for these services.
"Provided in Turkey": the definition
Article 2 defines a service as provided in Turkey when it is provided in Turkey, used in Turkey, aimed at persons in Turkey or evaluated in Turkey. The parenthesis on evaluation adds that if a digital advertising service is aimed at persons not in Turkey, the service is not treated as evaluated in Turkey.
For a buyer this suggests that two campaigns on one platform may not be assessed in the same way: one aimed at users in Turkey, one aimed only at an audience abroad. Which assessment applies follows from the platform's documentation.
The taxpayer under Law 7194
Article 3 names digital service providers as the taxpayers. The second paragraph of article 3 lets the Ministry hold parties to the taxable transactions, and those mediating the transaction and the payment, liable for payment of the tax where the taxpayer has no residence, workplace or legal seat in Turkey and in other cases deemed necessary.
Read together, the two paragraphs say the provider is the taxpayer and the ministry has a power to hold others liable in stated circumstances. How the power is used, whom it reaches and whether it has any consequence for your company is something the documentation does not state.
An exemption article exists
Article 4 sets exemptions tied to revenue limits and explains how they apply. The numeric limits can change, so check current rules before relying on them.
A SaaS invoicing startup: worked scenario
Example scenario: A small startup that sells invoicing software runs search ads on a foreign platform and buys one sponsored article on a foreign software review site. No amounts are used.
The platform spend
The finance lead sees the monthly spend in a statement. The statement shows that the issuing company is foreign. When sending it to bookkeeping she writes three notes: the campaign targets users in Turkey, payment was made with a company card, and the meaning of the tax line on the statement is unknown.
Bookkeeping answers with two questions: is the statement also an invoice, and which tax does the line reflect? The finance lead gets both answers from the platform's help pages and passes them on. She does not answer the VAT or digital services tax questions herself.
The review site
The review site sends an invoice from its own country. The agreement already says in writing to whom the invoice is made out, in what currency and on what date payment is due. The lead files agreement, invoice and bank slip in one folder.
What the targeting note solved
Later the startup launches a campaign aimed at an audience outside Turkey. Because article 2 of Law 7194 treats advertising aimed at persons outside Turkey differently in its wording, the lead keeps the two campaigns on separate lines in her notes and attaches the platform's audience report. Bookkeeping judges whether the records support the split.
Month-end pack
At the end of the month the finance lead sends bookkeeping a single pack: the platform statement, the review site's invoice, the card slips, the campaign notes and the saved terms. Each line has a three-row note naming the issuing company and its country, the type of service and the audience. Bookkeeping can raise all questions in one list instead of asking item by item.
Keeping the answers
When the answer arrives, the lead writes it on the same one-page summary. A later charge from the same platform starts from that page. If an answer changes, she adds the date and the reason. Over time the page becomes the startup's own record of how each kind of foreign spend was handled.
Reading the platform's own billing pages
Before an invoice reaches accounting, the platform's billing section shows several kinds of documents. The labels differ from platform to platform, so use the platform's own help pages to learn what each one is. Read the names exactly as they appear in the interface. If you use the platform in Turkish, the labels can look different.
Statement, invoice, receipt, payment confirmation
A statement lists charges for a period. An invoice is the document addressed to a named company. A receipt or payment confirmation shows that money was collected. A single charge can produce more than one of these, and each answers a different accounting question. Ask the platform which of its documents it presents as the invoice, and save that one first.
Which entity is named
The invoice names the legal entity that sold you the service. When a platform operates through different group companies, the named company may not be the one whose brand name you see in the advertising interface. Record the entity name on the first invoice and compare it on later ones. A change in the issuing entity is a reason to note it in the file before the next payment.
Settings that change the invoice
Billing country, company name, address and any tax details entered in the account settings feed into the invoice. Review them when the account is opened, and keep a dated note of the values at that time. If you correct the settings later, earlier invoices keep the earlier values.
Direct account, agency account, reseller
How the media is bought changes who issues what. Table: purchasing route and the document question.
| Route | Who issues the invoice | Point to settle |
|---|---|---|
| Direct account on the platform | The platform's issuing entity | Import and digital services tax questions both on the platform's invoice |
| Agency buys on your behalf | The agency, or the platform to the agency | Which document do we receive and to whom is it addressed? |
| Reseller or local partner | The reseller | Does the reseller invoice replace the platform document? |
| Publisher agreement, direct | The publisher | Which country and currency, and is a tax line shown? |
Putting the route into the contract
If an agency is involved, the agreement should say whose name the invoices carry, how frequently the agency reports, and what supporting statements it will hand over each month. The statute text on intermediary services in article 1 of Law 7194 is a reason to check whether the agency's role changes the analysis.
Reselling and re-invoicing
If your startup re-invoices ad spend to its own clients, that creates a second set of documents. Keep the supplier's invoice and your own re-invoice together and note how the two relate.
Points to settle before the first payment
Send these in writing so the answers are written too.
- Does the service we are buying count as an import of services?
- Under the VAT Law, who answers for the tax on this transaction, and in what capacity?
- Which tax does the tax line on the invoice reflect?
- Does the digital services tax raise any obligation for our company?
- Do we record campaigns aimed outside Turkey separately?
- Does the platform statement stand in for an invoice?
- When we buy through an agency, to whom is the invoice made out?
- On which date is foreign currency converted?
Why the order matters
The first three questions concern VAT, the fourth and fifth the digital services tax, and the rest the paper trail. Put the answers into a table and reuse it for later spend on the same platform.
Sorting answers by durability
After the meeting, sort the answers. Some are lasting rules, such as how this platform's invoice is booked. Some belong to one purchase only, such as the document requested for one campaign. Some are open, such as "ask the platform about the tax line". Marking the three kinds differently shows which answer can be reused next month. Give each open item a date for follow-up and attach the platform's reply to the summary, otherwise the question stays open for months.
Triage by type of spend
Table: type of spend, statute wording and the question that follows.
| Type of spend | Wording in the statute | Point to settle |
|---|---|---|
| Search or social ads | Advertising services provided in a digital environment | Do import and digital services tax questions both arise? |
| Ad measurement tool | Advertising control and performance measurement services | Is the tool's invoice treated as part of the advertising service? |
| Sponsored article on a foreign site | The reach of "advertising services" | Is sponsored content treated as advertising? |
| Listing on an interaction marketplace | Providing digital environments for user interaction | Which group does the listing fee fall in? |
| Media bought through an agency | Intermediary services | To whom is the invoice issued? |
Treat the third and fourth rows as questions, not answers.
Decision rule
- Is the supplier outside Turkey? If yes, open the import question as a separate item in your records.
- Is the service an advertising service provided digitally? If yes, add the digital services tax question.
- Is the campaign aimed at users in Turkey? Record the audience in writing.
- Is there a tax line? Ask the platform what it is.
- Do you hold an invoice or only a statement? Ask which counts.
Records that keep the file together
Four records complement each other: the agreement or platform terms, the invoice or statement, the bank or card slip, and a campaign note. For comparing quotes line by line, the scoring table in how to compare ad space offers helps. For costs the headline price leaves out, see backlink package prices and extra cost items. For an overview of invoices, VAT and withholding in marketing purchases, read the guide to marketing invoices in Turkey. If an agency buys on your behalf, the offer, contract and acceptance steps in the buying guide apply.
Checklist
- The issuing company and its country are written down.
- The billed party matches your company name or the agency's.
- The service description fits an advertising, publishing or other category.
- You asked what any tax line is.
- Currency, amount and date match the slip.
- The audience of the campaign is noted.
- The terms in force on the purchase date are saved as a PDF.
- The statement or invoice went to accounting in the same month.
Currency and timing
A charge in foreign currency appears in your books in lira terms, and the conversion date is a point to settle in your records. Your part is to place three things side by side: the currency and amount on the invoice, the amount on the bank or card slip, and the date of payment. If a card statement shows a different amount from the invoice, note the difference and send both documents, so nobody has to ask.
Account details
The company name and tax details on the ad account show up on invoices. If they are wrong, the invoice is addressed wrongly and fixing it later is harder. Check the name, address and any tax details against the documents when opening the account, and note the date of any change.
If there are only online terms
Where a platform offers online terms in place of a signed contract, save a dated PDF of the terms you accepted and mark the passages on who issues the invoice and how tax lines are shown. Save each new version when the terms change.
Wrong turns
Treating the card statement as the invoice
A card statement proves a charge, not the document behind it. Keep both, and ask whether the platform statement is accepted as an invoice.
Assuming the platform's tax line settles the matter
A tax line on a foreign invoice is a label printed by the supplier. It does not tell you which statute applies to your company or who answers for the tax. Put the label and the invoice side by side.
Folding two taxes into one line
The VAT Law and Law 7194 are separate. Putting both into one cell in your records hides which question was answered.
Leaving the targeting note unwritten
Article 2 of Law 7194 turns on whether the advertising is aimed at persons outside Turkey. If you did not record the audience when the campaign ran, rebuilding it months later is guesswork.
Letting the agency's report replace your own file
An agency's report is useful, but the invoice is addressed to a company and ends up in your books. Compare the report with the platform statement.
Frequently Asked Questions
Does a foreign advertising service fall under the VAT Law?
Article 1 of the VAT Law lists "every kind of goods and services import" among the transactions subject to VAT. Whether a particular advertising service counts as one depends on the service and on your business. This is not legal advice.
Who declares the VAT?
Article 9, paragraph 1 lets the Ministry hold parties to taxable transactions liable for payment, and says that VAT on electronic services supplied to individuals who are not VAT taxpayers is declared and paid by the suppliers.
What does the digital services tax cover?
Law 7194 taxes the revenue from listed digital services provided in Turkey. Advertising services provided in a digital environment are the first group in article 1.
Do advertisers pay the digital services tax?
In the statute the taxpayers are the digital service providers. The Ministry has a power to hold parties and intermediaries liable in stated circumstances. The documentation has no statement on how this applies to an advertiser.
What is the rate?
The documentation has no statement on a rate.
Is a platform statement an invoice?
That is a point to settle in your own records, together with the document type. Keep the statement together with the bank or card slip in the meantime.
Conclusion
Foreign advertising and publishing spend raises two separate questions: the VAT Law side, with its import wording and liability power, and the Law 7194 side, with its list of digital services and its definition of services provided in Turkey. Write both answers down, and keep invoice, statement, slip and campaign note together. This is not legal advice.
If you also look for placements in Turkey, you can compare options on the ad spaces page.
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