Turkey Customs Transaction Value: Article 24, Additions, Exclusions and Related Parties | 2026

1. Customs Law Articles 23–31 control customs value

Turkish customs valuation follows the statutory system in Customs Law No. 4458 Articles 23–31 and the implementing Customs Regulation. The Ministry of Trade’s customs-value guidance confirms that the transaction value is the price actually paid or payable in a sale for export to Türkiye after the adjustments required by Articles 27 and 28.

The valuation rules are distinct from tariff classification and origin. Classification identifies the GTIP; origin determines whether preferential or trade-policy treatment applies; customs value supplies the monetary base. A legally correct import declaration requires all three analyses to be correct at the same time.

The importer cannot select a valuation method simply because it produces the lowest taxable amount. The Customs Law establishes a hierarchy. Article 24 applies first when its conditions are satisfied. If it cannot be used, the next statutory methods are examined in the order set by the Law, subject to the specific sequencing rule for the deductive and computed-value methods.

2. Article 24 starts with the price actually paid or payable

Article 24 defines the transaction value by reference to the sale for export to Türkiye. The amount is not limited to the number printed on the commercial invoice. The legal concept covers the total payments made or to be made by the buyer to the seller or for the seller’s benefit for the imported goods, with the statutory adjustments.

For a straightforward arm’s-length purchase, the purchase invoice, sales contract and payment trail usually establish the starting figure. For group-company imports, licence arrangements, tooling supplied by the buyer, rebates, year-end price adjustments or multi-element supply contracts, the declared invoice price requires a deeper analysis.

A payment can affect customs value even when it is made to a party other than the seller if it discharges an obligation of the seller or is otherwise part of the price legally attributable to the imported goods.

3. The transaction value is accepted only when Article 24 conditions are met

The Ministry’s published guidance restates the Article 24 conditions. The buyer’s disposition or use of the goods must not be subject to disqualifying restrictions, other than the types of restrictions accepted by the Law. The sale or price must not depend on a condition or consideration for which a value cannot be determined. If part of the proceeds of a later resale, disposal or use accrues directly or indirectly to the seller, the necessary Article 27 adjustment must be possible.

The relationship between buyer and seller is also tested. A relationship does not create an automatic rejection. The statutory question is whether the transaction value remains acceptable under Article 24. The importer therefore needs evidence showing how the price was formed when the parties are related.

If a customs administration has reason to doubt the declared value, the importer’s response should address the actual statutory issue with contracts, invoices, payment records, pricing policies, comparable sales where legally relevant and technical allocation documents.

4. Related-party status does not automatically invalidate customs value

Multinational groups frequently assume that a transfer-pricing policy automatically proves customs value. That is incorrect. Corporate-income-tax transfer pricing and customs valuation serve different legal purposes. A transfer-pricing report is evidence, but Article 24 remains the customs-law test.

The importer should document whether the relationship affected the price. The contractual distribution model, price lists, sales to unrelated customers, margin policy, year-end adjustment mechanism and functions of the parties can become relevant. The customs file should also identify whether a later debit note, credit note or transfer-pricing adjustment changes the amount paid for the imported goods.

Where a group intends to make recurring post-import price adjustments, the customs consequences should be assessed before the first declaration instead of after a customs audit begins.

5. Article 27 requires additions that are not already included in the price

Article 27 is central because an invoice can be commercially correct but legally incomplete for customs valuation. The Law requires additions for specified elements to the extent that they are borne by the buyer and are not already included in the price actually paid or payable.

The categories include commissions and brokerage other than buying commissions, the cost of containers treated as one with the imported goods for customs purposes, packing costs including labour and materials, defined goods and services supplied directly or indirectly by the buyer free of charge or at reduced cost for production and sale for export, qualifying royalties and licence fees, and the part of proceeds from subsequent resale or use that accrues to the seller.

The importer must avoid double counting. If an Article 27 element is already included in the invoice price, it is not added a second time. The accounting file must show which elements are inside and outside the commercial price.

6. Royalties and licence fees require a contract-level analysis

Royalties are one of the most litigated valuation issues because a licence payment can relate to trademarks, patents, know-how, software, designs or other rights and can be paid to the seller or to another group company. The legal question is not resolved by the label used in the licence agreement.

The file must determine whether the payment relates to the imported goods and whether it satisfies the statutory conditions for addition to customs value. The relationship among the sales agreement, licence agreement, licensor, seller and buyer matters. A payment calculated as a percentage of Turkish net sales does not automatically fall outside customs value merely because it is paid after importation.

Foreign groups should map the contractual payment chain and preserve evidence explaining what right is licensed, which products generate the royalty and whether the sale for export depends on the licence arrangement.

7. Buyer-supplied tools, moulds, materials and engineering can be dutiable assists

Article 27 covers defined goods and services supplied by the buyer free of charge or at reduced cost for use in producing the imported goods. Typical risk items include materials incorporated into the product, tools, dies, moulds and similar items used in production, materials consumed in production and certain engineering, development, artwork, design work, plans and sketches undertaken outside Türkiye and necessary for production.

The cost must be allocated to the imported goods on a reasonable basis consistent with the legal rules. A mould used for a production run cannot simply disappear from customs value because the supplier did not invoice the importer for it.

A defensible calculation should identify acquisition or production cost, the quantity of goods over which the cost is allocated and the period or shipment methodology used.

8. Freight and insurance must be analysed to the legally relevant place

Transportation and insurance are not treated solely according to the Incoterm printed on the invoice. The Incoterm helps explain allocation of commercial cost and risk, but the Customs Law determines the customs-value treatment.

The import file should separate international freight, insurance, loading and handling connected with bringing the goods to the relevant Turkish border or entry point from post-import domestic transportation and other costs. When the invoice is on a delivered basis, the importer needs documents that permit legally excludable post-import amounts to be identified separately.

Freight invoices, insurance certificates, bills of lading, airway bills and forwarding statements should therefore be kept with the valuation file.

9. Article 28 identifies amounts excluded when the legal conditions are met

Article 28 prevents specified post-import or separately identifiable costs from being included in customs value when the statutory conditions are satisfied. The importer should document the amount and nature of each claimed exclusion rather than netting an unexplained figure from the invoice.

Typical analysis covers costs arising after importation, certain construction, erection, assembly, maintenance or technical assistance undertaken after import, and other items that the Law excludes when separately distinguished. Interest under a genuine financing arrangement also requires the specific statutory conditions to be tested.

The burden of a clear documentary trail remains practical reality: customs authorities must be able to identify the amount claimed as excluded and the contract or invoice basis for it.

10. If Article 24 fails, the statutory alternative methods apply

Rejection of the transaction value does not permit an arbitrary valuation. For the complete hierarchy, see our guide to the six customs valuation methods in Turkey. Customs Law provides the six customs valuation methods in Turkey in statutory sequence: transaction value, identical goods, similar goods, deductive value, computed value and the fallback method, subject to the sequencing rules written into the Law.

Each method has its own evidential conditions. Comparable import data must actually concern goods meeting the legal criteria. A domestic resale calculation must make the required deductions. A computed value needs reliable production-cost and profit information. The fallback method remains tied to the principles of the valuation system and is not a licence for unsupported estimates.

Where customs rejects Article 24, the written reasoning should identify why the primary method failed and how the replacement method was selected and calculated.

11. The valuation file should be built before clearance

A complete file normally contains the purchase contract, commercial invoice, purchase order, proof of payment, freight and insurance records, packing cost information, commission agreements, royalty and licence contracts, tool or mould records, supplied-material records, transfer-pricing documents where relevant, debit and credit notes, year-end adjustment policies and correspondence showing price formation.

For foreign-owned companies, the customs team should reconcile the declared value with intercompany accounting. A customs declaration based on one figure and a ledger that later settles a materially different product price is an audit trigger that requires a documented legal explanation.

Records should also show the exchange rate and declaration date used under the applicable customs rules.

12. Post-clearance control can revisit value after the goods are released

Release of the goods does not convert an incorrect customs value into a correct one. Customs authorities have statutory powers to review declarations and supporting commercial records. The practical focus often includes related-party pricing, royalties, assists, under-invoicing allegations, freight allocations and retroactive price adjustments.

The importer should therefore preserve the same evidence after clearance that it would need during initial examination. A group policy drafted only for tax purposes should be supplemented with customs-specific valuation analysis where the imported-goods price is affected.

If a later event changes the amount paid or payable, the company should determine the customs consequences promptly and follow the legally required correction or disclosure route.

13. Valuation disputes are subject to the Customs Law objection system

Where customs issues an additional assessment or penalty based on valuation, Article 242 provides the administrative objection route. The Ministry’s notice on legal remedies states that covered customs tax and penalty decisions are objected to within fifteen days from notification. Article 244 separately regulates customs reconciliation for eligible claims before an objection has been filed, subject to its exclusions and conditions.

A valuation objection should attack both the legal method and the arithmetic. It should identify the correct Article 24 analysis, the treatment of each disputed addition or exclusion, and the evidence supporting the declared amount. If customs used an alternative method, the objection should examine whether the legal preconditions and sequencing rules were respected.

14. Foreign seller checklist

Foreign sellers should give the Turkish importer documents that separate product price, freight, insurance, commissions, tooling, royalties and post-import services. Group companies should identify related-party relationships and year-end price mechanisms. Licence arrangements should be reviewed together with the sales contract. Product-development costs supplied by the buyer should be mapped before the first shipment.

When this work is done before import, customs value becomes a documented calculation rather than a figure reconstructed under audit pressure.

Conclusion

Customs valuation in Turkey starts with Customs Law Article 24 but does not end with the invoice. Articles 27 and 28 control additions and exclusions, and Articles 23–31 establish the complete valuation framework. Foreign traders should treat customs value as a transaction-level legal calculation supported by contracts, payment records and allocation evidence. Related-party pricing, royalties, assists and freight are the areas that require the strongest documentary control.

Frequently asked questions

What is the primary customs valuation method in Turkey?

The transaction-value method under Customs Law Article 24 is the primary method when its statutory conditions are satisfied.

Is the invoice price automatically the customs value?

No. The price actually paid or payable is adjusted under Articles 27 and 28.

Does a related-party sale automatically fail Article 24?

No. Related-party status triggers the statutory acceptability analysis; it does not automatically invalidate the price.

Are royalties always added?

No. Only royalties and licence fees meeting the Customs Law conditions are added.

Can buyer-provided moulds affect customs value?

Yes. Qualifying tools, dies, moulds and other assists supplied free or below cost are included through the Article 27 rules.

What happens if the transaction value cannot be used?

The alternative valuation methods in the Customs Law apply in the statutory order.

Does transfer pricing replace customs valuation?

No. Transfer-pricing documentation is evidence, but Customs Law Articles 23–31 govern customs value.

What is the objection period for a customs valuation assessment?

Customs Law Article 242 provides a fifteen-day administrative objection period from notification for covered customs tax and penalty decisions.

Can customs review value after release?

Yes. Post-clearance review can examine declarations and supporting commercial records.

Which records should foreign companies keep?

Contracts, invoices, payments, freight and insurance evidence, royalty agreements, assist records, pricing policies and allocation calculations should be retained together.

Official sources

Republic of Türkiye Ministry of Trade – Customs Value FAQ

Legal basis: Customs Law No. 4458 Articles 23–31, including Articles 24, 27 and 28. Source review date: 12 September 2026.

Related guides

• Transfer pricing in Turkey for foreign-owned companies
• International contracts and applicable law in Turkey