Customs Valuation Investigation in Turkey: What Documents Can Authorities Examine? — 2026 Current Guide

Learn which invoices, payment records, freight documents, royalties, transfer-pricing files and company records Turkish Customs can examine during a customs valuation investigation in 2026.

A customs valuation investigation in Turkey may begin during import clearance or after the goods have already been released. Turkish Customs can examine whether the declared customs value reflects the actual price paid or payable and whether legally relevant additions were omitted.

For international companies, the investigation may involve far more than the commercial invoice. Customs can review payment records, freight and insurance costs, royalties, commissions, assists, related-party transactions, transfer-pricing documents and accounting records.

An incorrect customs value may lead to additional customs duty, import VAT, interest, administrative penalties and disputes with suppliers or group companies.

What Is Customs Valuation?

Customs valuation is the process of determining the taxable value of imported goods. The primary method is generally the transaction value, meaning the price actually paid or payable, subject to legally required additions and conditions.

Where the transaction value cannot be accepted, Customs may consider alternative valuation methods based on:

• The value of identical goods;
• The value of similar goods;
• The deductive method;
• The computed value method;
• A fallback method applied in accordance with customs rules.

The importer must be able to explain how the declared value was calculated and why the selected valuation method is legally appropriate.

Why Does Turkish Customs Start an Investigation?

A valuation investigation may be triggered by:

• A very low invoice price;
• Significant differences between related-party and independent-party prices;
• Unusual discounts;
• Repeated amendments to invoices;
• Royalty or licence payments;
• Free-of-charge components;
• Inconsistent freight costs;
• Transfer-pricing adjustments;
• Differences between customs and accounting records;
• A declared value below reference or risk-analysis levels;
• Information received from foreign customs authorities;
• Post-clearance audit results.

A low price is not automatically unlawful. Customs should examine the commercial explanation, market conditions, product quality, contractual terms and evidence supporting the transaction.

Commercial Documents Customs Can Examine

Turkish Customs may request and compare:

• Commercial invoices;
• Pro forma invoices;
• Purchase orders;
• Sales contracts;
• Distribution agreements;
• Framework supply agreements;
• Price lists;
• Discount schedules;
• Credit notes;
• Debit notes;
• Packing lists;
• Bills of lading;
• Airway bills;
• Insurance policies;
• Freight invoices;
• Customs declarations;
• Warehouse records;
• Delivery notes;
• Correspondence concerning price negotiations.

The invoice should correspond to the goods actually imported. Differences in product description, quantity, model, unit price or delivery terms may cause Customs to question the declared value.

Bank and Payment Records

Payment evidence is often central to a valuation investigation. Customs may examine:

• Bank transfer records;
• Swift messages;
• Letters of credit;
• Payment schedules;
• Advance-payment records;
• Offset arrangements;
• Intercompany account statements;
• Credit-card or platform payments;
• Settlement agreements;
• Payment to third parties;
• Currency conversion records.

The amount transferred may differ from the invoice amount for legitimate reasons, such as a deposit, credit note, warranty adjustment or payment of freight. The importer should provide a clear reconciliation rather than leaving differences unexplained.

Payments made to a person other than the seller can be particularly important. Customs may investigate whether the payment represents part of the purchase price, a commission, a royalty or another addition to customs value.

Freight, Insurance and Delivery Costs

Customs may review whether freight and insurance costs were correctly included up to the Turkish customs border.

Relevant documents include:

• Freight invoices;
• Insurance certificates;
• Charter-party or transport contracts;
• Incoterms provisions;
• Carrier statements;
• Port and terminal charges;
• Demurrage invoices;
• Inland transport records;
• Cost-allocation schedules.

The correct treatment may depend on the delivery term. For example, the valuation analysis can differ where the contract uses EXW, FOB, CIF, CPT or DDP terms.

The importer should explain how international freight, insurance and post-importation transport were separated.

Royalties and Licence Fees

Royalty and licence payments may be added to the customs value where they relate to the imported goods and are a condition of sale, subject to the applicable legal assessment.

Customs may examine:

• Trademark licence agreements;
• Patent and technology agreements;
• Franchise agreements;
• Software licence contracts;
• Technical-assistance agreements;
• Royalty invoices;
• Sales-based royalty calculations;
• Payments to licensors;
• Group intellectual-property arrangements.

Not every royalty is automatically included. The legal and factual connection between the payment and the imported goods must be analysed carefully.

The importer should prepare a product-by-product assessment explaining whether the payment relates to the imported goods, post-importation activity, domestic sales or unrelated services.

Assists and Free-of-Charge Materials

An assist is an item or service supplied by the buyer, directly or indirectly, for use in producing the imported goods. Customs may examine whether the following were provided without charge or at reduced cost:

• Components;
• Moulds and dies;
• Tools;
• Production equipment;
• Design work;
• Engineering services;
• Materials;
• Packaging;
• Artwork;
• Technical plans.

The importer may need to allocate the value of the assist across the relevant shipments. Records should show how the calculation was made and which imports were affected.

Related-Party Transactions

Where the importer and exporter are related companies, Turkish Customs may investigate whether the relationship influenced the price.

Customs may examine:

• Shareholding structures;
• Group organisation charts;
• Intercompany agreements;
• Transfer-pricing policies;
• Comparable uncontrolled prices;
• Resale-price analyses;
• Cost-plus calculations;
• Profit margins;
• Year-end transfer-pricing adjustments;
• Board or management decisions;
• Group financing arrangements.

Being related does not automatically make the customs value unacceptable. The importer should demonstrate that the transaction value is consistent with commercial circumstances and that the relationship did not distort the price.

Transfer-pricing compliance and customs valuation are connected but not identical. A price acceptable for income-tax purposes may still require a separate customs analysis.

Accounting and Corporate Records

During a post-clearance audit, Customs may examine:

• General ledgers;
• Purchase ledgers;
• Inventory records;
• Accounts payable;
• Cost accounting records;
• Stock movement reports;
• Management accounts;
• Annual financial statements;
• Audit reports;
• ERP data;
• Customs reconciliation schedules;
• VAT records;
• Import cost calculations.

The importer should ensure that accounting records reconcile with customs declarations. Repeated differences may be treated as evidence of undervaluation or incomplete declaration.

Digital Data and Electronic Records

In 2026, customs investigations increasingly involve electronic records. Customs may compare declaration data with:

• E-invoices;
• E-ledgers;
• ERP records;
• Bank data;
• Freight platforms;
• Electronic warehouse systems;
• Supplier portals;
• Customs broker software;
• Electronic certificates;
• Digital correspondence.

Companies should preserve original electronic files and metadata where possible. A spreadsheet prepared after the investigation may be less persuasive than contemporaneous ERP and accounting records.

Confidential information should be provided through a secure and authorised channel. The company should verify the legal basis and scope of the information request before disclosing sensitive group data.

What Happens If Customs Rejects the Declared Value?

If Customs concludes that the declared value is unacceptable, it may reassess:

• Customs duty;
• Additional customs duties;
• Import VAT;
• Anti-dumping or safeguard duties;
• Interest;
• Administrative penalties.

The importer should request a detailed explanation of the valuation method used. Customs should identify why the transaction value was rejected and how the alternative value was calculated.

A reference price or risk indicator should not automatically replace the legally required valuation analysis. The importer may challenge an assessment that lacks a sufficient factual explanation or ignores relevant commercial evidence.

Limitation and Post-Clearance Control

Goods may be investigated after release from customs. Under the general framework of Customs Law No. 4458, under-assessed customs duties may generally be notified within three years from the date the customs debt arose, subject to statutory exceptions.

The importer should review:

• The date of each customs declaration;
• The date the customs debt arose;
• The date of notification;
• Any interruption or suspension of limitation;
• Whether criminal allegations affect the period;
• Whether the audit covers unrelated declarations.

A company should not provide broad historical data without understanding the scope of the investigation.

How Can the Importer Respond?

The importer should:

1. Obtain the written information request or assessment.
2. Confirm the declarations and products covered.
3. Appoint one coordinated response team.
4. Preserve accounting and electronic records.
5. Reconcile invoices with bank payments.
6. Explain discounts and credit notes.
7. Review freight and insurance additions.
8. Analyse royalties and assists.
9. Prepare related-party documentation.
10. Request clarification of the valuation method.
11. Respond within the stated deadline.
12. Obtain legal advice before accepting an adjustment.

The response should be factual and consistent. Documents should not be altered, backdated or recreated.

Challenging a Customs Valuation Assessment

The importer may challenge:

• Rejection of the transaction value;
• Use of an incorrect valuation method;
• Failure to consider commercial discounts;
• Incorrect inclusion of royalties;
• Incorrect treatment of assists;
• Miscalculation of freight;
• Incorrect treatment of related-party pricing;
• Import VAT calculation;
• Penalty calculation;
• Notification or limitation defects.

Under Article 242 of Customs Law No. 4458, an objection is generally filed within 15 days from lawful notification of the customs decision.

If the objection is rejected, the importer may bring proceedings before the competent tax court within the applicable procedural period. Filing an objection or lawsuit does not automatically suspend collection. A separate suspension-of-execution request may be required where immediate payment would cause serious and difficult-to-repair harm.

Settlement may be available for certain customs debts and penalties, but the company should compare settlement with litigation and possible contractual recovery from the exporter.

Frequently Asked Questions (FAQ)

1. Can Turkish Customs inspect bank transfers during a valuation investigation?

Yes. Bank records may be reviewed to compare the actual payments with the declared invoice value.

2. Can Customs request transfer-pricing documents?

Yes, especially where the importer and exporter are related companies or year-end price adjustments exist.

3. Are royalties always added to customs value?

No. The connection between the royalty, the imported goods and the sale must be assessed under the applicable rules.

4. Can free-of-charge moulds or components increase customs value?

Potentially yes. Their value may be treated as an assist if they were supplied for producing the imported goods.

5. Can Customs reject a low invoice price automatically?

No. A low price may trigger scrutiny, but the importer should be given an opportunity to explain and prove the commercial basis.

6. Can post-import transport costs be excluded from customs value?

Possibly, if they are properly identified and separated from costs incurred up to the Turkish customs border.

7. Can Customs inspect ERP and e-invoice records?

Yes. Electronic accounting, warehouse and invoicing records may be examined during post-clearance control.

8. How far back can a customs valuation investigation go?

The general assessment period is commonly three years, subject to statutory exceptions and special circumstances.

9. What is the Turkish objection deadline?

An objection is generally filed within 15 days from lawful notification under Article 242 of Customs Law No. 4458.

10. Can an importer challenge the valuation method used by Customs?

Yes. The importer may challenge the rejection of transaction value, the alternative method, additions and the calculation of duties and penalties.

This article is intended for general informational purposes only. To avoid any loss of rights, we recommend consulting your lawyer regarding your specific circumstances.

Legal Support for Customs Valuation Investigations

Fırat Fesih Kaya Law Office, advises international companies, foreign exporters, Turkish importers, manufacturers, distributors and logistics providers.

Lawyer Fırat Fesih Kaya can assist with customs valuation audits, invoice and payment analysis, royalty and assist assessments, related-party transactions, transfer-pricing coordination, additional-duty disputes, administrative objections and tax-court proceedings.

For urgent legal support:

Mobile / WhatsApp: +90 532 769 22 22
Office: +90 312 434 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yıldırım Tower, Balgat, Çankaya / Ankara, Turkey