Company Books Seized in Turkey: Criminal Investigation Guide for Foreign Directors 2026

Company books seized during a criminal or tax investigation in Turkey? Learn what foreign directors should do about accounting records, search and seizure, digital evidence, false invoice allegations, tax inspections and criminal defense in 2026.

When Turkish authorities obtain or seize a company’s accounting books, invoices, electronic records, computers or financial documents during a criminal investigation, foreign directors often face two immediate problems: understanding why the records were taken and ensuring that the company’s own evidence is preserved before the investigation develops further.

The first point is particularly important because not every request for company books is a criminal seizure.

During an ordinary tax inspection, Turkish tax legislation generally allows the authorities to request necessary books and documents in writing. The Tax Inspection Board explains that tax inspections are principally conducted at the authority’s office and that the taxpayer may be formally requested to produce the necessary books and documents. Failure to produce requested material within the specified period without a justified excuse can have legal consequences.

A criminal seizure is different.

If company books, computers or records have been taken as evidence in a criminal investigation, foreign directors should determine the exact procedural basis for the measure rather than treating it as an ordinary tax-document request.

The immediate strategy should be:

Identify the legal basis → Determine exactly what was taken → Preserve the company’s remaining evidence → Reconstruct the disputed transactions → Establish individual responsibility → Review the legality and scope of the seizure.

Why Can Company Books Become Criminal Evidence?

Company books can provide a detailed reconstruction of a business.

Depending on the allegations, investigators may use them to examine:

• Purchases
• Sales
• Suppliers
• Customers
• VAT records
• Cash transactions
• Shareholder accounts
• Related-company transactions
• Inventory
• Bank payments
• Loans
• Expenses
• Invoices
• Tax declarations

In a suspected tax crime, the records may be compared against bank movements, electronic invoices, supplier records, customs documentation, warehouse information and digital communications.

Company books are therefore rarely examined in isolation.

First Question: Were the Books Requested or Seized?

Foreign directors should establish this immediately.

There is an important difference between:

“Produce your books for a tax inspection.”

and:

“These books are being seized as evidence in a criminal investigation.”

The Tax Inspection Board confirms that ordinary tax inspections generally involve written requests for books and documents and that taxpayers may be required to submit them within the specified period.

A criminal seizure, by contrast, involves criminal-procedure rules and should be examined according to the particular decision, authority and circumstances.

Do Not Describe Every Tax Inspection as a Criminal Investigation

This mistake can create unnecessary panic.

A company may be:

• Subject to risk analysis
• Asked for information
• Subject to field verification
• Selected for tax inspection
• Investigated for a suspected tax crime

These stages are not interchangeable.

Turkey’s current KURGAN system is particularly relevant in 2026. The Tax Inspection Board expressly describes KURGAN as a risk-analysis mechanism rather than an inspection or sanction by itself. It does not automatically classify a purchaser as a false-document user or a seller as a false-document issuer.

Why Are Foreign-Owned Companies Receiving More Transaction Questions?

Tax enforcement has become increasingly data-driven.

Under the Tax Inspection Board’s current false-document monitoring program, transactions involving goods and services are analyzed individually, taxpayers may receive information requests, and field verification may be conducted where appropriate. Taxpayers are given an opportunity to explain the commercial reality of transactions and provide supporting documentation.

The scale is substantial.

On August 21, 2026, the Tax Inspection Board announced that information requests had been sent to 34,315 taxpayers in one phase of its false-document monitoring program based on historical KURGAN risk outputs. Importantly, the Board expressly stated that a KURGAN risk signal alone does not establish that a transaction is false or that the taxpayer used a false document.

For a foreign director, that distinction can become central:

Risk signal is not the same as criminal proof.

What Should a Foreign Director Do Immediately After Company Books Are Seized?

The first priority is not to provide speculative explanations.

It is to understand the file.

Determine:

Which authority took the records?

When?

From where?

Under which investigation?

Which records were taken?

Which years are involved?

Which transactions are being investigated?

Is the company itself under tax inspection?

Is the director personally a suspect?

These questions should be answered before the company constructs its substantive defense.

Obtain an Exact Inventory of What Was Taken

A vague statement such as:

“They took our accounting records.”

is insufficient.

Prepare an internal inventory.

For example:

Item	Period	Location	Importance
General ledger	2024	Accounting office	Core accounting
Purchase invoices	2025	Archive	Supplier investigation
Laptop	Current	Finance director	Accounting/email access
External drive	2023–2025	Server room	Backups
Supplier contracts	2025	Procurement	Transaction evidence

This can later become essential when analyzing the prosecution evidence.

Preserve Copies That Lawfully Remain Available

The company may have lawful copies or backups of relevant records.

These can include:

• Electronic accounting records
• Electronic invoices
• Bank statements
• Contracts
• Emails
• Enterprise-system records
• Warehouse records
• Customs documents
• Delivery records
• Procurement files

Do not modify the material.

Preserve it in its existing form.

The objective is to maintain an independent record of the company’s evidence.

Never Reconstruct Missing Evidence by Fabricating It

If a document cannot be found, do not create a replacement and present it as contemporaneous.

Foreign directors should never:

• Backdate contracts
• Create false delivery documents
• Alter invoices
• Change accounting entries
• Manufacture warehouse records
• Delete unfavorable emails
• Fabricate supplier correspondence

A defense based on genuine incomplete evidence is safer than a defense contaminated by manufactured documents.

Why Were the Books Seized?

The answer usually depends on the underlying allegation.

Common tax-related allegations may involve:

• False invoices
• Misleading invoices
• Fictitious suppliers
• Concealed transactions
• Unrecorded sales
• Suspicious cash movements
• Related-party transactions
• Accounting irregularities
• Concealment of records

The defense should identify the precise suspected conduct rather than simply using the broad phrase “tax crime.”

False Invoice Investigation

Suppose investigators suspect that the company recorded invoices for goods that never existed.

The books may show:

Invoice → Accounting entry → VAT treatment → Payment.

But the defense should look beyond accounting.

Ask:

Were the goods actually ordered?

Were they transported?

Did they enter the warehouse?

Were they used in production?

Were they subsequently sold?

Was payment genuine?

The commercial reality of the transaction can be decisive.

KURGAN and Proof of Genuine Transactions

The Tax Inspection Board’s current KURGAN guidance expressly recognizes that taxpayers can provide evidence establishing the reality of transactions. It also explains that assessment of intent in false-document-use examinations is carried out according to specified criteria within the tax-inspection framework.

Accordingly, a foreign director should not limit the defense to:

“The invoice is in our books.”

Instead, reconstruct:

Commercial need → Supplier → Order → Delivery/service → Payment → Inventory/use → Accounting treatment.

Company Books Can Also Help the Defense

Seized books are not automatically evidence against the company.

They may show:

• Consistent inventory
• Genuine payments
• Regular accounting
• Real purchases
• Genuine customers
• Normal pricing
• Corresponding sales
• Production consumption

The same accounting records used by investigators may contain exculpatory evidence.

Compare the Books With Bank Records

Banking evidence can provide an independent layer of verification.

For each disputed transaction, determine:

• Payment date
• Amount
• Recipient
• Payment description
• Account used
• Who authorized payment
• Whether payment was returned
• Whether unusual onward transfers occurred

Bank evidence should then be compared with the accounting entry.

Circular Transactions Require Particular Attention

Suppose the books show a TRY 5 million supplier payment.

Bank records show:

Company → Supplier → Related company → Company shareholder.

That movement may generate substantial questions.

If there is a legitimate commercial explanation, preserve the documents establishing it.

Do not invent one after the investigation begins.

Compare the Books With Physical Inventory

For goods transactions, inventory can be extremely important.

Suppose the disputed invoice concerns:

1,000 industrial components.

The defense may examine:

Warehouse receipt → Stock entry → Production consumption → Finished product.

If independent operational evidence supports the accounting record, it can materially affect the analysis.

Compare the Books With Customs Records

Foreign-owned companies frequently import goods.

Relevant evidence may include:

• Customs declarations
• Commercial invoices
• Packing lists
• Bills of lading
• Air waybills
• Freight records
• Import payments
• Warehouse receipts

Customs documentation can provide independent evidence concerning whether goods actually entered Turkey.

Service Invoices Require Different Evidence

Services do not generate warehouse records.

For consultancy, software, marketing, engineering or management services, preserve:

• Agreements
• Project files
• Reports
• Presentations
• Emails
• Meeting records
• Software deliverables
• Timesheets
• Technical documentation

An invoice alone may not establish whether a service genuinely occurred.

Who Was Responsible for the Accounting Records?

This question is particularly important for foreign directors.

Identify:

• Who maintained the books?
• Who entered invoices?
• Who communicated with the accountant?
• Who approved expenses?
• Who submitted supporting documents?
• Who controlled accounting software?
• Who prepared tax declarations?

A foreign director may have formal authority but limited operational involvement.

Alternatively, the director may personally control finance.

The evidence should determine which situation existed.

Company Director Does Not Automatically Mean Accounting Operator

A foreign director may be responsible for:

• International sales
• Investment strategy
• Manufacturing
• Parent-company relations

while local personnel manage:

• Accounting
• Procurement
• Tax compliance
• Supplier payments

Corporate title alone should not replace evidence concerning actual conduct.

But “The Accountant Did Everything” Is Not Enough

A generic attempt to transfer responsibility to an accountant can be ineffective.

Investigators may ask:

Who gave the invoice to the accountant?

Who selected the supplier?

Who approved payment?

Who confirmed delivery?

Who benefited from the transaction?

The entire decision chain should be reconstructed.

Create a Responsibility Matrix

A useful defense tool is a historical responsibility table.

Function	Responsible Person	Director Involvement
Supplier selection	Procurement manager	None
Delivery confirmation	Warehouse manager	None
Invoice entry	Accounting department	None
Payment approval	Finance director + foreign director	Limited
Tax declaration	External accountant	None

This should reflect reality, not be created to manufacture distance from the transaction.

Historical Responsibility Is More Important Than Current Titles

Investigations frequently concern earlier years.

The company’s current finance manager may not have worked there at the relevant time.

The current foreign director may have been appointed after the transaction.

Reconstruct the organization for each relevant period.

Foreign Director Appointed After the Disputed Transactions

Suppose:

2023 — disputed invoices

2024 — accounting entries and declarations

2025 — foreign investor acquires company

2026 — foreign director appointed

A 2026 investigation should not obscure that chronology.

Preserve:

• Share acquisition documents
• Appointment resolution
• Trade registry records
• Signature authority
• Employment agreement
• Bank authorization dates

What If the Director Resigned Before the Transactions?

Preserve evidence showing when authority ended.

Relevant documents can include:

• Resignation
• Board resolution
• Trade registry records
• Signature cancellation
• Bank mandate changes

Precise dates can become decisive.

Electronic Accounting Records

Modern companies often maintain both statutory accounting material and electronic records.

Investigators may compare:

• Statutory books
• Electronic invoices
• Accounting software
• Enterprise systems
• Bank data
• Emails
• Internal spreadsheets

Differences between these systems should be explained carefully.

Not every discrepancy automatically demonstrates criminal manipulation, but unexplained inconsistencies can become important evidence.

Computers Seized Together With Company Books

If accounting computers, laptops or external drives were seized, digital-search rules become relevant.

In February 2026, the Constitutional Court issued a major decision concerning Article 134 of the Criminal Procedure Code, which governs searches, copying and seizure involving computers, computer programs and computer data. The Court annulled specified portions of the provision because it found the statutory safeguards inadequate in areas including handling of digital data, protection of personal information, retention and destruction, and legal remedies. The Court delayed the annulment’s effect for nine months from publication in the Official Gazette.

Because that transition period is relevant during 2026, the exact law in force on the date of a particular digital search should be checked carefully rather than assuming that every search is governed by the same version of Article 134.

Why the 2026 Digital Evidence Decision Matters

A company laptop can contain far more than accounting records.

It may include:

• Employee information
• Customer databases
• Trade secrets
• Legal communications
• Personal messages
• Parent-company information
• Unrelated transactions

The Constitutional Court specifically emphasized the intensive privacy and personal-data implications of digital searches and the need for appropriate safeguards.

Foreign directors should therefore document precisely which digital devices were seized and how they were handled.

Physical Device and User Identity Are Different

If suspicious accounting files are discovered on a laptop, ask:

Who used the laptop?

Was it shared?

Was remote access enabled?

Which user created the file?

When was it created?

Who modified it?

A file found on a company device does not automatically establish that a particular foreign director created it.

Accounting Software Access Logs

Where available, system logs can be valuable.

They may show:

• User accounts
• Login times
• Entries created
• Changes made
• Approval actions

This can help identify the actual operator.

Cloud Accounting Systems

Multinational companies may use cloud systems hosted outside Turkey.

Relevant questions can include:

• Where data is stored
• Which employees have access
• Parent-company administrator access
• User logs
• Backup records
• Whether data is local or remote

The fact that a Turkish office can access a foreign cloud platform should not be confused automatically with local physical possession of every remote record.

Do Not Remotely Delete Cloud Data

After a seizure, headquarters personnel should not attempt to “protect” the company by deleting cloud files accessible from Turkey.

Preservation is critical.

If scope, confidentiality or privilege issues exist, they should be addressed through lawful procedures rather than evidence destruction.

Legal Communications Found Among Company Records

Corporate records may contain communications with lawyers.

If potentially privileged legal communications are captured during a broad seizure, identify them promptly.

Do not assume that every document found among company records has identical legal status.

Trade Secrets and Unrelated Corporate Information

Foreign companies may worry that seized systems contain:

• Pricing strategies
• Customer lists
• Acquisition plans
• Proprietary technology
• Parent-company information

These concerns should be documented and addressed through the applicable procedural mechanisms.

However, confidentiality concerns do not justify deleting or concealing evidence.

What If the Authorities Take Original Books Needed for Business?

The company may still need information for:

• Current accounting
• Payroll
• Tax filings
• Audits
• Customer disputes
• Banking
• Corporate reporting

Determine what lawful copies or backups remain available and whether access or return can appropriately be requested.

Business continuity should be managed without interfering with the investigation.

Failure to Produce Books Is a Separate Risk

Foreign directors should distinguish seizure from failure to produce records.

The Tax Inspection Board explains that under Article 139 of the Tax Procedure Law, taxpayers can be requested in writing to produce necessary books and documents, and those who fail without justified excuse to produce them within the specified period are treated as not having produced them. A justified excuse may permit additional time.

Accordingly:

“The authorities already have some of our documents”

should not automatically be treated as an answer to every later document request.

Determine precisely which authority possesses which records.

What If the Books Are Already With Another Authority?

Document that fact.

Identify:

• Authority holding them
• Date taken
• Record or receipt
• Investigation number
• Exact materials

Do not simply ignore a later request.

Explain the factual situation through the appropriate procedure.

What If Books Were Lost Before the Investigation?

Do not fabricate replacements.

Investigate the genuine reason:

• Fire
• Flood
• Server failure
• Theft
• Physical loss
• Former accountant
• Data corruption

Then identify independent evidence and backups.

The legal consequences depend heavily on the facts.

Search and Seizure Versus Tax Inspection

Foreign directors should maintain this distinction throughout the case.

Tax inspection: primarily determines tax compliance and correct tax liability.

Criminal investigation: investigates whether a criminal offence was committed and who is responsible.

The same books may be relevant to both proceedings, but the legal questions are not identical.

Can the Foreign Director Personally Become a Suspect?

Yes, potentially.

But individual responsibility should be established separately.

Investigators may examine:

• Signature authority
• Procurement involvement
• Payment approval
• Accounting instructions
• Supplier communications
• Financial benefit
• Knowledge of irregularities

Share ownership or directorship alone does not answer these questions.

Foreign Shareholder Versus Foreign Director

A foreign shareholder may be passive.

A foreign director may have operational control.

A person may be both.

Do not use the labels interchangeably.

The defense should identify what the individual actually did during the relevant period.

Statements to Police or Prosecutor

If a foreign director is called to provide a statement, the first task is to understand the allegation and procedural status.

Before providing detailed explanations, identify:

• Relevant transactions
• Relevant periods
• Disputed invoices
• Books seized
• Manager’s role
• Existing documentary evidence

Avoid speculation.

Do not guess about accounting entries you did not personally make.

Foreign-Language Records

Multinational companies frequently maintain records in several languages.

Preserve originals.

Examples include:

• English emails
• German parent-company reports
• Arabic supplier communications
• Chinese purchase documents
• Russian technical records

Translations may be needed during proceedings, but originals should remain preserved.

Can Company Books Prove That a Transaction Was Genuine?

Potentially, but usually the strongest evidence comes from combining multiple independent sources.

For example:

Accounting entry + bank payment + freight record + warehouse entry + production consumption

is more informative than:

Invoice alone.

The defense should reconstruct the complete commercial chain.

2026 False Invoice Risk Analysis

The Tax Inspection Board currently explains that taxpayers identified through KURGAN may still establish the reality of transactions through evidence during the inspection process.

This makes contemporaneous records particularly important.

Foreign directors should preserve:

Contract → Order → Delivery → Payment → Inventory → Production/resale → Accounting.

2026 Explanation Procedure

Where the statutory conditions are satisfied, certain preliminary findings concerning false-document use may fall within Turkey’s explanation procedure.

The Tax Inspection Board currently states that for 2026, where the allegedly used false-document amount does not exceed TRY 870,000—or even if it exceeds that amount, does not exceed 5% of total purchases of goods and services—the taxpayer may potentially qualify for the procedure, subject to the remaining statutory requirements.

This procedure should not be confused with a criminal acquittal or automatic termination of every possible investigation.

The exact procedural stage should be identified.

Do Not Assume Seizure Means Conviction

Seizure is an evidence-preservation or investigative measure.

The prosecution must still establish the elements of the alleged offence and the individual defendant’s responsibility according to the applicable evidentiary standard.

The defense should therefore examine both:

How the evidence was obtained

and

What the evidence actually proves.

20-Step Immediate Action Plan for Foreign Directors

1. Determine which authority took the company books.
2. Identify whether this was a tax request, search or criminal seizure.
3. Obtain available records concerning the measure.
4. Prepare an exact inventory of seized material.
5. Identify the tax periods involved.
6. Identify disputed suppliers and transactions.
7. Preserve lawful copies and backups.
8. Preserve bank statements.
9. Preserve contracts and purchase orders.
10. Preserve transportation documents.
11. Preserve warehouse and inventory evidence.
12. Preserve customs records.
13. Preserve service deliverables.
14. Preserve emails and messaging records.
15. Identify who controlled accounting.
16. Identify who controlled procurement and payments.
17. Reconstruct the historical corporate organization.
18. Do not delete or alter evidence.
19. Review the legality and scope of any digital search or seizure.
20. Coordinate the tax and criminal defense strategies.

Frequently Asked Questions

1. Can Turkish authorities seize a foreign-owned company’s accounting books?

Company records can become subject to criminal investigative measures where the applicable legal requirements are satisfied. However, an ordinary written request to produce books during a tax inspection should be distinguished from criminal seizure.

2. Does seizure of company books mean that tax evasion has been proven?

No. Seizure is an investigative measure. The books and other evidence must still be analyzed, and individual criminal responsibility must be established separately.

3. Is a foreign director automatically responsible for everything recorded in the company’s books?

No. The person’s actual responsibilities, knowledge, authority and conduct should be examined.

4. What if an external accountant maintained all the books?

The accountant’s role is relevant, but the investigation should also determine who supplied invoices, approved transactions, authorized payments and controlled the underlying commercial activity.

5. Can computers be seized together with accounting books?

Digital devices can become subject to criminal investigative measures where the statutory conditions are met. Digital searches require particular attention in 2026 because the Constitutional Court annulled specified parts of Article 134 of the Criminal Procedure Code with delayed effect. The law applicable on the exact search date should therefore be verified.

6. Should the company delete sensitive files before authorities examine them?

No. Do not delete, alter, conceal or remotely wipe potential evidence after becoming aware of an investigation.

7. What if the foreign director joined the company after the disputed transactions?

Appointment dates, acquisition documents, signature authority, banking authority and historical organizational records should be preserved. Current directorship does not by itself prove participation in earlier conduct.

8. Is a KURGAN risk signal proof of a false invoice?

No. The Tax Inspection Board expressly states that KURGAN is a risk-analysis mechanism and that its outputs do not themselves establish that the purchaser used a false document or that a particular transaction was false.

9. What evidence can show that a disputed transaction was genuine?

Depending on the transaction, contracts, bank transfers, freight records, customs documents, warehouse entries, inventory movements, production records, emails and service deliverables can be important.

10. What should a foreign director do first after learning that company books were seized?

Identify exactly what was taken and why, preserve remaining evidence, determine the relevant transactions and periods, reconstruct internal responsibility and assess both the substantive tax allegation and the legality of the criminal investigative measures.

2026 Current Position for Foreign Directors

Turkey’s tax enforcement environment in 2026 increasingly combines accounting information, transaction-level risk analysis and physical verification.

KURGAN analyzes potentially risky transactions but, according to the Tax Inspection Board itself, does not by itself determine criminal or tax guilt.

The August 2026 false-document monitoring results demonstrate the scale of this approach: 34,315 taxpayers received information requests in that phase alone, while the Board expressly reiterated that risk outputs are not themselves proof of false transactions.

At the same time, digital evidence has become an important procedural issue. The Constitutional Court’s 2026 ruling concerning computer searches and seizures identified shortcomings in statutory safeguards relating to digital data and ordered specified portions of Article 134 annulled with delayed effect.

For foreign directors, this means that a strong defense should examine two separate dimensions:

Substantive defense: Were the transactions genuine, and what did the director personally know or do?

Procedural defense: How were the books, computers and other evidence obtained, preserved, examined and attributed?

Both can materially affect the case.

Legal Assistance for Foreign Directors After Company Books Are Seized in Turkey

The seizure of company books can place a foreign director at the intersection of tax law, criminal procedure, corporate governance and digital evidence.

A comprehensive defense may require determining:

Why were the books taken?

Which transactions are under investigation?

Are the allegedly suspicious transactions genuine?

Who controlled accounting and procurement?

What was the foreign director’s actual role?

Were computers and electronic records also seized?

Were the investigative measures lawfully authorized and properly executed?

Which evidence supports the defense?

Fırat Fesih Kaya Law Office provides legal assistance to foreign company directors, investors, shareholders and executives facing tax-related and corporate criminal investigations in Turkey.

Lawyer Fırat Fesih Kaya assists foreign clients with company-book seizures, tax crime investigations, false invoice allegations, searches of company premises, digital evidence, accounting and banking records, prosecutor proceedings and the preparation of individualized criminal defense strategies.

Early intervention can be particularly important because the seizure of the company’s records does not mean the defense should wait passively. Independent commercial evidence, historical authority records, bank documents, delivery evidence and digital information may need to be preserved promptly before ordinary business retention processes cause them to disappear.

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

This publication is provided for general informational purposes and does not constitute legal advice. The legality of a document request, search, seizure, digital examination or tax-related criminal investigation depends on the law in force on the relevant date, the procedural decision, alleged offence, individual corporate role and evidence in each case.