Turkish authorities attach company machinery, vehicles, inventory or other assets for customs debt. Learn how foreign investors can challenge the debt, object to unlawful or excessive attachment, seek urgent relief and prevent sale of seized assets.

A customs dispute in Turkey can escalate from an additional duty assessment or administrative penalty into compulsory collection against the company’s assets.

The authorities may seek attachment of:

• Machinery;
• Vehicles;
• Inventory;
• Equipment;
• Commercial receivables;
• Real estate;
• Other corporate assets and rights.

For a foreign investor, attachment can threaten much more than the amount of the customs debt. Seizure of essential machinery, vehicles or inventory may interrupt production, prevent deliveries and create serious liquidity problems.

Unpaid customs duties may be collected under Law No. 6183 on the Collection Procedure of Public Receivables. Ministry guidance confirms that, under Article 62 of Law No. 6183, movable and immovable assets, receivables and rights may be attached up to an amount sufficient to satisfy the public receivable.

The recommended emergency strategy is:

Identify the attached assets → obtain the complete collection file → verify the underlying customs debt → examine notification and finality → determine whether the attachment exceeds the collectible debt → challenge the appropriate collection measure → seek urgent suspension where available → prevent sale of attached assets → protect business continuity.

1. First Identify Exactly What Has Been Attached

Prepare an immediate inventory.

Record:

• Asset;
• Location;
• Ownership;
• Estimated value;
• Attachment date;
• Collection file;
• Whether the asset is essential to operations.

Do not rely only on verbal information from company personnel.

2. Obtain the Attachment Record

Request the official documentation showing:

• Which authority imposed the attachment;
• Customs debt concerned;
• Amount being collected;
• Assets attached;
• Valuation attributed to those assets.

The attachment itself must be connected to an identifiable public receivable.

3. Trace the Debt Back to the Original Customs Declaration

Reconstruct the entire chain:

Customs declaration

→ additional assessment

→ administrative penalty

→ notification

→ administrative objection

→ court proceedings

→ finality

→ payment order

→ attachment.

A procedural defect earlier in this chain can materially affect the collection analysis.

4. Determine Whether the Customs Debt Was Legally Collectible

This is one of the first questions foreign investors should examine.

A customs assessment and a legally collectible public debt are not always the same thing.

Check whether:

• Administrative remedies were completed;
• Litigation was filed;
• Litigation remains pending;
• A court cancelled or reduced the assessment;
• The debt had actually reached the compulsory-collection stage.

5. Check the Original Notification

A company may discover the customs problem only after assets are attached.

Obtain evidence concerning service of:

• Additional assessment;
• Penalty decision;
• Objection decision;
• Payment order.

If the administration relies on an earlier notification to establish finality, that notification should be reviewed carefully.

6. Electronic Notification Should Also Be Checked

Foreign-owned companies should not assume that the absence of a physical letter means that no valid notification occurred.

Review the company’s official electronic notification records and determine exactly when each relevant document was legally served.

7. Obtain the Payment Order

Before compulsory collection reaches attachment, the collection file may contain a payment order or another legally relevant demand.

Obtain the complete document.

Record:

principal

penalties

late-payment amounts

total debt

notification date.

8. Separate the Underlying Customs Debt From the Attachment

There may now be two different legal issues:

Was the customs assessment itself lawful?

and

Was attachment lawfully imposed and properly limited?

Do not treat them as one question.

9. Law No. 6183 Becomes Central at the Collection Stage

Ministry guidance expressly states that customs duties not paid within the applicable period are pursued under Law No. 6183.

Therefore, once attachment begins, the company’s strategy must combine customs law with public-receivables collection law.

10. Article 62 Is Particularly Important

Under the collection framework described by the Ministry, the administration may attach the debtor’s movable and immovable property, receivables and rights in an amount sufficient to satisfy the public receivable.

The phrase “sufficient to satisfy the public receivable” is particularly important when evaluating excessive attachment.

11. Calculate the Actual Collectible Debt

Prepare an independent reconciliation:

Principal customs debt

legally applicable penalties

late-payment amounts

−

payments

−

amounts cancelled or reduced

=

actual outstanding amount.

Do not accept the enforcement figure without verification.

12. Check Whether the Debt Was Already Paid

Obtain:

• Bank records;
• Customs receipts;
• Accounting records;
• Payment references.

A payment may exist but may not have been correctly matched to the collection file.

13. Check Whether the Debt Was Reduced by a Court

Suppose Customs originally assessed TRY 20 million.

If subsequent proceedings reduced the collectible amount to TRY 8 million, enforcement should be reconciled with the actual judicial result.

Obtain the complete judgment rather than relying on a summary.

14. Review Settlement History

If a customs settlement occurred, determine:

• Which declarations were included;
• Agreed principal;
• Agreed penalties;
• Amount paid.

The enforcement file should correspond to the settlement outcome.

15. Existing Security Must Be Considered

The company may already have provided:

• Cash security;
• Bank guarantee;
• Comprehensive guarantee;
• Another accepted security.

Determine whether the administration is holding significant security while simultaneously attaching additional corporate assets.

16. Is the Attachment Excessive?

This is a crucial issue.

Suppose:

Collectible customs debt: TRY 10 million

while assets worth approximately:

TRY 35 million

have been attached.

The company should immediately analyze whether the scope of enforcement exceeds what is necessary to secure collection.

The statutory collection framework contemplates attachment sufficient to cover the public receivable rather than unlimited attachment of corporate property.

17. Prepare an Asset Valuation Table

For example:

Asset	Estimated Value	Operational Importance
Production Machine A	TRY 8 million	Critical
Vehicle Fleet	TRY 4 million	High
Inventory	TRY 7 million	Critical
Equipment	TRY 3 million	Medium

Independent valuation evidence may be useful where the administration’s valuation or overall scope of attachment is disputed.

18. Operational Importance Should Be Documented

If Customs attaches a machine essential to the company’s only production line, explain this specifically.

Document:

• Daily production capacity;
• Customer orders;
• Replacement difficulty;
• Employee dependency;
• Expected shutdown losses.

This may become important in an urgent relief application.

19. Inventory Attachment Can Create Immediate Commercial Damage

Attachment of finished products or raw materials may prevent:

• Production;
• Customer delivery;
• Export;
• Resale.

Document the exact goods and commercial commitments affected.

20. Vehicle Attachment Can Disrupt Operations

Company vehicles may be essential for:

• Distribution;
• Field operations;
• Logistics;
• Technical services.

Prepare evidence showing which vehicles are genuinely operationally necessary.

21. Real Estate Attachment Requires Separate Attention

If the collection extends to company land, factories or commercial premises, obtain:

• Title records;
• Attachment details;
• Property valuation;
• Existing mortgages and encumbrances.

The company’s overall security structure should be reviewed.

22. Third-Party Receivables May Also Be Targeted

Public-debt collection can extend to the debtor’s receivables and rights. Ministry guidance specifically refers to attachment of receivables and rights as well as movable and immovable property.

Therefore, determine whether customers or other third parties have also received attachment notices.

23. Asset Attachment Can Progress Toward Sale

Attachment should never be treated as merely symbolic.

Official Ministry activity in 2026 confirms that movable property attached under Law No. 6183 can proceed to public auction.

Once a sale process advances, recovery of the physical asset may become substantially more difficult.

24. Monitor the Sale Stage Separately

Determine whether:

• Assets have only been attached;
• Valuation has occurred;
• Sale has been scheduled;
• Auction has been announced.

The closer the case moves toward sale, the more urgent the response becomes.

25. Obtain Any Auction or Sale Notice Immediately

If sale proceedings have begun, obtain:

• Sale date;
• Asset description;
• Valuation;
• Auction conditions;
• First and subsequent sale information.

Do not assume that challenging the original customs debt automatically stops a scheduled sale.

26. Seek Suspension Where Legally Available

Depending on the procedural posture, the company should assess whether suspension of execution or another urgent judicial measure can be sought.

The application should address both:

the apparent unlawfulness of the collection measure

and

the serious or difficult-to-repair consequences of continued enforcement.

27. Demonstrate Irreparable Operational Consequences

Strong evidence can include:

• Production schedules;
• Customer contracts;
• Delivery deadlines;
• Payroll obligations;
• Export orders;
• Financing arrangements.

Explain concretely why sale or continued restraint of the asset would cause harm that cannot easily be reversed.

28. Do Not Assume Filing a Case Automatically Stops Sale

Whether a particular challenge suspends collection or sale depends on the legal route and procedural stage.

The company should specifically determine whether separate interim protection is necessary.

29. Challenge Excessive Attachment Directly Where Appropriate

Even where some customs debt is valid, that does not automatically justify every enforcement measure.

A company may accept:

TRY 5 million debt

while disputing:

TRY 20 million of attached assets.

These are separate issues.

30. Consider Substitution of Security

Depending on the circumstances and applicable collection procedure, it may be commercially preferable to investigate whether an attached operational asset can be released against another acceptable form of security.

This can be particularly important where machinery is worth substantially more than the debt but is essential for production.

31. Do Not Provide Duplicate Security

Before offering additional security, calculate:

existing guarantees

cash security

bank attachment

attached assets.

The company should understand its total exposure.

32. Third-Party-Owned Assets Require Immediate Review

An asset located at the company’s premises may actually belong to:

• Leasing company;
• Supplier;
• Shareholder;
• Another group company.

Ownership should be established with reliable documents.

The legal owner may need to pursue the appropriate third-party remedy.

33. Leasing Arrangements Should Be Documented

For leased machinery or vehicles, preserve:

• Lease agreement;
• Invoices;
• Registration;
• Payment records;
• Delivery records.

Mere possession by the customs debtor does not necessarily resolve ownership.

34. Foreign Parent Company Assets Require Separate Analysis

A Turkish subsidiary and its foreign parent are generally distinct legal persons.

If assets belonging to another group entity are affected, determine the legal basis immediately.

Do not assume group ownership automatically permits collection.

35. Shareholder Assets Are Not Automatically Company Assets

Similarly, an unpaid corporate customs debt does not automatically transform every shareholder asset into property available for collection.

Any attempt to extend liability should be reviewed under the specific statutory framework.

36. Director Liability Requires Separate Legal Grounds

If collection moves from the company to directors or legal representatives, examine:

• Relevant period;
• Representative status;
• Statutory basis;
• Procedural prerequisites.

Do not treat personal liability as automatic.

37. Limitation Should Be Reviewed

Examine separately:

limitation concerning assessment or notification of the customs debt

and

limitation concerning collection of a finalized public receivable.

A company should not confuse these two periods.

38. Do Not Transfer Assets Artificially

After enforcement becomes foreseeable, artificial transfers intended to defeat collection can create additional legal exposure.

Foreign investors should use lawful remedies:

• Objection;
• Litigation;
• Suspension;
• Security substitution;
• Excess-attachment challenge.

39. Document Business Interruption Risk

If attachment threatens production, prepare a quantified estimate.

Include:

daily production loss

employee costs

customer penalties

replacement costs

lost orders.

This can strengthen the urgency evidence even where those losses are not automatically recoverable.

40. Review All Customs Debts

One attachment may indicate that several historical customs assessments have entered collection.

Perform a company-wide review immediately.

Otherwise, assets released from one attachment may shortly become subject to another.

41. Build a Declaration-by-Declaration Enforcement Matrix

For each customs debt record:

Declaration

Assessment

Penalty

Notification

Objection

Court case

Final amount

Payment order

Attachment

Sale status.

This can reveal procedural errors quickly.

42. Coordinate Customs and Collection Counsel

The customs merits and enforcement procedure must be handled together.

Classification, origin or customs-value arguments may explain why the original debt is wrong, while public-debt rules determine whether the current attachment can proceed.

43. Foreign Investors Should Inform Headquarters Immediately

Prepare a concise corporate report stating:

Debt claimed

Amount disputed

Assets attached

Estimated asset value

Sale status

Legal challenge

Urgent relief requested

Operational impact.

This is particularly important where the attachment affects investment continuity.

44. Act Before the Asset Is Sold

The practical position changes significantly once attached property enters and completes the sale process.

The Ministry continues to conduct public auctions of movable assets attached under Law No. 6183 in 2026.

Early action is therefore substantially more effective than attempting to reconstruct the dispute after disposal.

45. Emergency Strategy After Company Assets Are Attached

The recommended sequence is:

Identify every attached asset

→ obtain attachment records

→ obtain the payment order

→ retrieve the underlying customs assessments

→ review notification

→ review objections and litigation

→ determine whether the debt is legally collectible

→ calculate the actual outstanding amount

→ check existing security

→ compare debt with attached asset value

→ challenge excessive or unlawful attachment

→ seek urgent suspension where available

→ prevent auction or sale

→ protect essential operating assets

→ review all other customs debts.

25-Point Asset Attachment Checklist

1. Identify every attached asset.
2. Obtain attachment records.
3. Identify the collection authority.
4. Record attachment dates.
5. Obtain the payment order.
6. Identify underlying declarations.
7. Obtain customs assessments.
8. Review penalties.
9. Review notification records.
10. Review administrative objections.
11. Review court proceedings.
12. Determine whether the debt became collectible.
13. Calculate the actual outstanding debt.
14. Check previous payments.
15. Check customs security.
16. Value attached assets.
17. Identify excessive attachment.
18. Identify third-party-owned assets.
19. Document operational importance.
20. Check whether sale has been scheduled.
21. Obtain auction notices.
22. Assess suspension of execution.
23. Consider lawful security substitution.
24. Review related customs debts.
25. Act before attached property is sold.

Frequently Asked Questions

1. Can Turkish Customs attach company assets for unpaid customs duties?

Yes. Once customs duties become collectible public receivables, compulsory collection under Law No. 6183 may include attachment of movable and immovable property, receivables and rights. Ministry guidance confirms this collection framework.

2. Can foreign investors challenge the attachment?

Potentially, yes. The appropriate remedy depends on the underlying debt, notification history, payment order, procedural finality and the specific attachment measure.

3. Can Customs attach assets worth much more than the debt?

The collection framework refers to attachment of property sufficient to satisfy the public receivable. Where the overall attachment materially exceeds the collectible amount, the scope of enforcement should be reviewed urgently.

4. What if the customs debt itself is wrong?

The company should review whether the underlying assessment remains challengeable and whether existing administrative or judicial proceedings affect collectability. The customs merits and enforcement proceedings must be coordinated.

5. Can attached machinery be sold?

Attached movable property can proceed to public sale under the applicable collection framework. The Ministry published public-auction notices for movable assets attached under Law No. 6183 in 2026.

6. Can the company stop the auction by filing a lawsuit?

Not automatically in every case. The company should determine whether the selected remedy suspends enforcement or whether separate interim judicial protection must be requested.

7. What if the attached machinery belongs to a leasing company?

Ownership should be documented immediately. The actual owner may need to use the appropriate third-party procedure to protect its rights.

8. Can the foreign shareholder’s personal property automatically be attached?

Corporate debt does not by itself establish automatic shareholder liability. Any extension of collection to shareholders or representatives requires a specific legal basis and separate analysis.

9. Can alternative security be offered to release essential machinery?

Depending on the procedural circumstances, replacement or alternative security may be worth examining. Existing guarantees and other attachments should first be calculated to avoid unnecessary duplicate security.

10. What is the most urgent issue after receiving an attachment notice?

Determine whether the customs debt was legally collectible, calculate whether the attachment exceeds the actual debt and establish whether the attached assets are already moving toward public sale. Once an auction process advances, the need for urgent legal action becomes significantly greater.

Client-Focused Legal Support for Customs Asset Attachments in Turkey

Customs collection disputes may involve:

Company asset attachment

Machinery seizure

Vehicle attachment

Inventory attachment

Customs payment orders

Excessive attachment

Public-debt enforcement

Suspension of execution

Third-party ownership

and public auction of attached assets.

Fırat Fesih Kaya Law Office assists foreign investors, multinational companies, manufacturers and importers whose corporate assets are attached because of customs debts in Turkey.

Lawyer Fırat Fesih Kaya provides legal assistance in reviewing customs assessments and collection files, challenging unlawful or excessive attachments, protecting third-party-owned assets, seeking urgent suspension measures and taking legal action to prevent the sale of essential corporate property.

Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower, Office No:148, 06520 Balgat, Çankaya, Ankara, Turkey