What Is the Difference Between e-Dispatch Notes and e-Invoices? Can They Be Used Interchangeably?

What Is the Difference Between e-Dispatch Notes and e-Invoices? Can They Be Used Interchangeably?

 

 

     e-Dispatch Notes (e-İrsaliye) and e-Invoices (e-Fatura) are two types of electronic documents that are sometimes confused because of their different purposes and areas of use. In this article, we explain the main differences between these two e-documents and clarify when each one should be used.

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  • An e-Dispatch Note documents the shipment and transportation of goods, while an e-Invoice documents the sale and the amount charged. Therefore, an e-Dispatch Note cannot replace an invoice.

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  • For an e-Invoice or e-Archive Invoice to serve as a dispatch note, it must be issued at the time of delivery, include the exact hour and minute of issuance, contain the statement “Serves as a dispatch note”, and have a signed paper copy transported together with the goods.

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  • As a general rule, an invoice for sold goods must be issued within 7 days at the latest from the delivery date. Issuing an e-Dispatch Note does not eliminate or change this invoicing obligation.

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  • A dispatch note must also be issued for shipments that take place without a sale, such as transfers between warehouses, goods sent for subcontracted production, and consignment deliveries.

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  • Being an e-Invoice user does not automatically mean that a business is required to use e-Dispatch Notes. The obligation depends on the company's business activity and the applicable gross sales revenue thresholds.

 

e-Dispatch Notes and e-Invoices are two important documents used in commercial transactions, but they differ in terms of their purpose, legal validity, and application. So, what exactly distinguishes these two electronic documents, and when can one be used instead of the other? Here are the details.

 

 

Can an e-Dispatch Note Replace an Invoice?

 

     No. An e-Dispatch Note cannot replace an invoice. While an e-Dispatch Note documents the shipment of goods, an invoice records the sale. Therefore, an invoice must also be issued for goods covered by an e-Dispatch Note. The invoice must be issued within 7 days at the latest from the delivery date (VUK Article 231/5).

 

However, the reverse is possible. An e-Invoice or e-Archive Invoice containing the statement “Serves as a dispatch note” can replace a dispatch note if the required conditions are met (Communiqué No. 509 of the Tax Procedure Law – VUK).

 

 

What Is an e-Dispatch Note?

 

     An e-Dispatch Note is an official electronic document issued when goods that have been sold or are intended to be sold are transported from one location to another. In other words, it is the electronic version of the traditional paper dispatch note. From a legal perspective, there is no difference between an e-Dispatch Note and a paper dispatch note.

 

A dispatch note is a document used to record the necessary information about goods while they are being transported from one location to another. It contains information such as the owner of the goods, quantity, destination address, and information about the parties involved. An e-Dispatch Note must be issued before the shipment begins and does not have to include price information.

 

Under the latest regulations issued by the Revenue Administration, businesses with gross sales revenue of TL 10 million or more for the 2021 and subsequent fiscal years are required to transition to the e-Dispatch Note system.

 

 

What Is an e-Invoice?

 

     An e-Invoice is an electronic document that enables an invoice to be prepared, delivered to the customer, and tracked digitally. Today, many businesses use e-Invoices either because they are legally required to do so or voluntarily, allowing them to manage their invoicing processes electronically.

 

According to the regulations published by the Revenue Administration, taxpayers with gross sales revenue of TL 3 million or more in the 2022 and subsequent fiscal years are required to use e-Invoices.

 

An e-Invoice can only be issued when both the seller and the buyer are registered e-Invoice users with the Revenue Administration. If the buyer is not registered in the system, an e-Archive Invoice must be issued instead. Both documents show the sales amount and VAT and serve as supporting documents for tax declarations.

 

 

Key Differences Between e-Dispatch Notes and e-Invoices

 

     The primary difference between an e-Dispatch Note and an e-Invoice lies in their purpose. An e-Dispatch Note documents the movement and shipment of goods, whereas an e-Invoice records the sale and the financial value of the transaction.

 

As a general rule, a business must be an e-Invoice taxpayer in order to use e-Dispatch Notes. However, special regulations apply to businesses operating in the iron and steel sector. Conversely, being an e-Invoice user does not by itself create an obligation to use e-Dispatch Notes.

 

     The method used by a business to access the e-Invoice system must also be used for e-Dispatch Notes. For example, if a company issues e-Invoices through a private integrator, it can also manage its e-Dispatch Notes through the same private integrator.

 

 

Criterion e-Dispatch Note e-Invoice
Purpose Documents the shipment and transportation of goods. Documents the sale and the sales amount.
When is it issued? Before the goods are shipped. During or after delivery of the goods.
Time limit Cannot be issued retroactively. Must be issued within 7 days from delivery (VUK Article 231/5).
Amount and VAT Not mandatory. Mandatory.
Can it be used without a sale? Yes. It can be used for warehouse transfers, subcontracting, and consignment transactions. No.
Who is required to use it? e-Invoice users with gross sales revenue of TL 10 million or more, as well as businesses in the iron and steel sector and other specified sectors. Taxpayers with gross sales revenue of TL 3 million or more and businesses in certain sectors.
Buyer process The buyer can send an acceptance, partial acceptance, or rejection response within 7 days from the actual shipment date. For commercial invoices, the buyer may accept or reject the invoice within 8 days. There is no system-based rejection for basic invoices.
Rejection / objection The sender cannot cancel it. The buyer can reject it only before the actual shipment. Commercial invoices can be rejected; basic invoices can be challenged through a return invoice, notary, or registered electronic mail (KEP).
Legal basis VUK Article 230 and Communiqué No. 509 of the Tax Procedure Law VUK Articles 229–231 and Communiqué No. 509 of the Tax Procedure Law

 

 

What Does “Serves as a Dispatch Note” Mean?

 

     The statement “Serves as a dispatch note” indicates that the invoice can also function as a dispatch note. If an invoice containing this statement meets the required conditions and is carried together with the goods, there is no need to issue a separate paper or e-Dispatch Note. Its paper equivalent is an invoice with a dispatch note function.

 

According to Communiqué No. 509 of the Tax Procedure Law, all of the following conditions must be fulfilled for an electronic invoice to be used instead of a dispatch note:

         

         The invoice must be issued at the time of delivery and before the shipment begins.

 

          In addition to the invoice date, the exact hour and minute of issuance must be stated.

 

         The document must contain the statement “Serves as a dispatch note.”

 

         A paper copy of the invoice must be signed by the seller or an authorized person and transported together with the goods.

 

     e-Invoice users who are also subject to the e-Dispatch Note system can benefit from this practice as well. If an e-Invoice or e-Archive Invoice is issued at the time of delivery in accordance with the above conditions, there is no need to issue a separate e-Dispatch Note. However, if the invoice is issued after delivery, the statement cannot be used.

 

 

How Is the Statement Added to an e-Invoice or e-Archive Invoice?

 

     The statement can be added to the “Notes” section of the invoice as “Serves as a dispatch note.” In many e-transformation software solutions, selecting the “invoice with dispatch note” option while creating the invoice allows the invoice to function as a dispatch note as well.

 

The same rules apply to e-Archive Invoices. However, since an e-Archive Invoice is issued to buyers who are not registered in the e-Invoice system, a stamped and signed paper copy must be transported together with the goods.

 

 

Can the Statement Be Used for Shipments Made by Cargo?

 

     The Revenue Administration has clarified this issue in an official ruling. According to the ruling issued by the Istanbul Tax Office Directorate on January 16, 2017, with reference number 11395140-105[mük.257-2016/VUK-1-19889]-13502, an e-Invoice user shipping products by cargo may use a signed e-Invoice printout containing the statement “Serves as a dispatch note” as a dispatch note without obtaining additional permission.

 

However, the ruling establishes two important conditions:

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  • The invoice must be issued at the time of delivery. If the goods are shipped after the invoice date due to warehouse workload, customer requests, or similar reasons, this practice cannot be used.

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  • If an invoice is not issued at the time of delivery, a dispatch note must be prepared. In this case, a dispatch note must be issued pursuant to VUK Article 230/5, and its date and number must be stated on the e-Invoice issued later.

 

The ruling was based on Communiqué No. 433 of the Tax Procedure Law, which was in force at the time. The same provisions are currently included in Communiqué No. 509.

 

 

Can an e-Invoice or e-Archive Invoice Replace a Dispatch Note?

 

     The question “Can an e-Invoice be used instead of an e-Dispatch Note?” is frequently asked. If an e-Invoice or e-Archive Invoice is issued at the time the goods are delivered, includes the exact hour and minute alongside the issue date, and contains the statement “Serves as a dispatch note,” the document can also be used as a dispatch note.

 

If a signed printout of the invoice is transported together with the goods, there is no need to issue a separate e-Dispatch Note.

 

     Since an e-Archive Invoice is issued to buyers who are not registered in the e-Invoice system, the buyer does not receive the document through the Revenue Administration's system. Therefore, the signed printout carried with the goods serves as the physical document during transportation. If the goods are inspected and the printout does not contain the required statement or time information, the shipment may be considered to have been made without a valid dispatch note.

 

Can These Documents Replace One Another?

 

 

Document Can it replace a dispatch note? Can it replace an invoice? Required condition
e-Dispatch Note — No A separate invoice must be issued within 7 days after delivery.
e-Invoice (with the required statement) Yes — It must be issued at delivery, include the exact hour and minute, and its signed printout must accompany the goods.
e-Archive Invoice (with the required statement) Yes — The same conditions apply.
e-Invoice / e-Archive Invoice issued after delivery No — A separate dispatch note is required for shipment.
Paper invoice with dispatch note Yes Yes Applicable only to taxpayers who are not subject to mandatory e-document requirements.

 

 

What Should Be Done When an Invoice Cannot Replace a Dispatch Note?

 

     An invoice containing the statement “Serves as a dispatch note” can only be used when the sale and shipment take place simultaneously. In the following situations, an e-Dispatch Note must be issued for the shipment; if the business is outside the scope of the e-Dispatch Note requirement, a paper dispatch note should be used instead:

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  • When the goods are shipped first and the invoice is issued within the following 7 days.

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  • For shipments where there is no sale, such as transfers between the company's own warehouses or branches, goods sent for subcontracted production, and consignment deliveries.

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  • For partial shipments, when goods covered by the same invoice are transported on different days or by multiple vehicles.

 

 

Can a Paper Dispatch Note Be Used When an e-Dispatch Note Cannot Be Issued?

 

     If an e-Dispatch Note cannot be issued due to infrastructure or technical problems, a paper dispatch note may be prepared. However, in such cases, the paper dispatch note and the e-Dispatch Note must be created simultaneously.

 

The paper dispatch note must include the document number of the e-Dispatch Note, the issue date, and the exact hour and minute. In addition, the statement “The e-Dispatch Note has also been issued.” must be included on the document.

 

 

Are e-Dispatch Note Users Required to Use e-Invoices?

 

     Yes. As a general rule, businesses must be registered in the e-Invoice system in order to issue e-Dispatch Notes. However, an exception was introduced by the Revenue Administration in 2022.

 

Taxpayers engaged in the manufacture, import, or export of iron and steel (GTIP 72) and articles made of iron or steel (GTIP 73), excluding taxpayers under the simple taxation procedure, are required to join the e-Dispatch Note system even if they are not registered in the e-Invoice system.

 

 

Scope Threshold (gross sales revenue) Transition date
e-Invoice, general TL 3 million and above (2022 and subsequent years) July 1 of the year following the year in which the threshold is exceeded
e-Invoice, online sales, real estate and motor vehicle sectors TL 500,000 and above Same rule applies
e-Dispatch Note, general Registered e-Invoice user and TL 10 million or more (2021 and subsequent years) July 1 of the year following the year in which the threshold is exceeded
e-Dispatch Note, iron and steel (GTIP 72 and 73 manufacturing, import, and export; excluding simple taxation) No threshold; e-Invoice registration is not required Within the periods specified in the relevant communiqué
e-Dispatch Note, Construction Iron Monitoring System TL 1 million and above (2024 and subsequent years) July 1 of the year following the year in which the threshold is exceeded
e-Dispatch Note, other sectors No threshold Within the periods specified in the relevant communiqué

 

     For example, a business whose gross sales revenue exceeds TL 10 million in 2025 must start issuing e-Dispatch Notes as of July 1, 2026. For businesses exceeding this threshold in 2026, the deadline is July 1, 2027.

 

These thresholds are based on Communiqué No. 509 of the Tax Procedure Law and subsequent amendments to the communiqué.

 

 

Within How Many Days Must an e-Dispatch Note Be Invoiced?

 

     An invoice for goods covered by an e-Dispatch Note must be issued within 7 days at the latest from the delivery date. This period is calculated from the actual shipment date stated on the e-Dispatch Note.

 

Under VUK Article 231/5, an invoice that is not issued within this 7-day period is considered as if it had never been issued.

 

     If an invoice is deemed not to have been issued at all, a special irregularity penalty may be imposed under VUK Article 353/1. The penalty is 10% of the invoice amount and, as of 2026, cannot be less than TL 17,000 for the first finding. The minimum threshold increases for repeated findings (Communiqué No. 588 of the Tax Procedure Law). In addition, the failure to fully declare sales revenue and VAT may create a risk of tax loss.

 

     There is also a deadline for the buyer. If no response is submitted to the e-Dispatch Note within 7 days, the goods are deemed to have been fully received. If there is a shortage or excess in the delivered goods, the appropriate dispatch note response must be submitted within this period, and the invoice should be issued accordingly.

 

      If several shipments are made to the same customer within short intervals, the relevant dispatch notes can be combined into a single invoice. However, because the 7-day invoicing period starts from the earliest delivery date, the date of the first dispatch note must be carefully monitored when consolidated invoicing is used.


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