What Is a Free-of-Charge Export Invoice?

 

According to the Export Regulation, free-of-charge export is defined as the sale and delivery of goods abroad without receiving any payment in return for the delivery of the goods.

In the Communiqué on Free-of-Charge Exports published in the Official Gazette, the goods that may be exported free of charge are listed as follows:

 

a) Gifts carried or sent by real or legal persons; samples in quantities appropriate to commercial practices; advertising and promotional goods; imported goods and packaging materials subject to reuse or recycling,
 

b) Parts, wastage, and components of goods previously exported in accordance with procedures and sent free of charge in line with commercial customs and practices, as well as parts that must be replaced within the warranty period for goods exported under warranty,
 

c) Goods and vehicles carried, sent, or sent on behalf of foreign mission members, foreigners working in Türkiye, Turkish citizens moving their households abroad, and public officials assigned permanently or temporarily abroad, provided that these situations are documented by the relevant authorities,
 

ç) Goods and vehicles carried, sent, or sent on behalf of legal entities established abroad, foreign tourists, and Turkish citizens residing abroad,
 

d) Goods and vehicles sent by public institutions and organizations, municipalities, and universities in accordance with their duties or agreements,
 

e) Humanitarian aid supplies sent by public institutions and organizations, municipalities, universities, the Turkish Red Crescent, and associations and foundations operating for public benefit in cases of war, earthquakes, floods, epidemics, famine, and similar disasters.

 

For cases not covered by these provisions, the opinion of the Undersecretariat of Foreign Trade is obtained, and the process is carried out by the relevant customs administration.

 

As with domestic sales, exports also require proper documentation. Therefore, a company exporting goods abroad is obliged to issue an export invoice, even in cases of free-of-charge exports. Since a transfer of goods takes place, issuing an invoice is mandatory even if no payment is received.

Although the goods are exported free of charge, they still have an actual cost and are held in inventory. For this reason, accounting records for free-of-charge export invoices must be made. The cost of the goods is calculated, recorded as an expense, and deducted from inventory.

 

 

How Is a Free-of-Charge Export Invoice Issued?

 

Having explained what a free-of-charge export invoice is, let’s move on to how it is issued.

In free-of-charge export transactions where no payment is received from abroad, invoices indicating that the transfer is free of charge or has a zero value used to be issued, since no receivable or liability arose.

However, this practice caused accounting issues for exporting companies, leading to amendments in the relevant regulations. With these changes, it was decided that free-of-charge exports would be carried out using a document other than a standard commercial invoice.

Under the updated regulations, it has become mandatory to issue an invoice stating that the value of the exported goods or services is zero or free of charge.

A free-of-charge export invoice issued with a zero amount may be submitted to the relevant customs authority together with a document showing the value, containing the exporting company’s full legal name, address, tax identification number, and the signature of the authorized company representative.

According to the General Communiqué of the Tax Procedure Law, taxpayers keeping books on a balance-sheet basis are required to report purchases of goods and services exceeding certain thresholds using the Purchases of Goods and Services Notification Form (Form Ba) and sales of goods and services using the Sales of Goods and Services Notification Form (Form Bs). In other words, free-of-charge export invoices are subject to Ba/Bs reporting obligations.

Although value-added tax (VAT) is not calculated for goods exported outside the borders of Türkiye, purchases or sales of goods and services exceeding TRY 5,000 must still be declared in the Ba-Bs forms.

 

 

Are Free-of-Charge Export Invoices Covered by the e-Invoice System?

 

In free-of-charge export transactions, the requirement to issue an export invoice is determined based on the customs declaration. If an invoice is not issued as an attachment to the customs declaration, e-Archive invoice users are required to issue an e-Archive invoice. Taxpayers outside this scope were previously able to issue paper invoices. However, as of 2026, paper invoices will be completely phased out, and all invoices issued by non–e-Invoice taxpayers must be issued as e-Archive invoices, regardless of the amount.

In cases where free-of-charge goods are exported under the supervision of the Ministry of Customs and the Ministry of Labor, issuing an e-Invoice is mandatory. Within the e-Invoice system, it is possible to issue free-of-charge invoices just as with paper invoices.

Taxpayers issuing free-of-charge export invoices must enter “zero” in the payableAmount field and select the “free-of-charge” category when preparing the customs declaration in the Information System.