Geri
Songül PINAR
Gümrük Müşaviri & Teşvik Uzmanı
As is known, the terms "Customs Duty" and "Customs Duties" have different meanings under our legislation. Specifically, "customs duty" refers to a single tax calculated based on the rates and principles specified in the customs tariff in effect on the date the customs obligation arises. In contrast, "customs duties" refer to the entirety of import or export taxes applicable to the goods. These taxes are listed in the annex to the Customs Reconciliation Regulation as follows: Customs Duty, Additional Customs Duty, Specific and Fixed Duties, Anti-Dumping Duty, Countervailing Duty, Value Added Tax (VAT), Special Consumption Tax (SCT), Additional Financial Obligation, Mass Housing Fund, Tobacco Fund, Additional Fund, Resource Utilization Support Fund, Environmental Contribution Fee, Compensatory Duty (for exports), and TRT Bandrol Fee (for non-commercial goods).
Thus, DFIF—the subject of this article—is not classified among customs duties.
The Support and Price Stability Fund (DFIF) was established at the Central Bank of the Republic of Turkey on the basis of Article 2 of Law No. 2976, dated February 2, 1984, on the Regulation of Foreign Trade, to ensure that foreign trade is conducted in accordance with economic conditions.
The authority to regulate this fund has been granted to the Ministry of Trade.
The sources of this fund include:
- Deductions and collections from export revenues based on weight, quantity, or value, taking into account domestic and international price developments for all types of goods;
- Exchange rate differences collected during export transactions under the legislation on the Protection of the Value of Turkish Currency;
- The net assets of DFIF established under Decree No. 30 concerning the Protection of the Value of Turkish Currency.
Export is an activity that brings foreign currency into the country. Therefore, various institutions and organizations provide different facilities and advantages for export-related transactions. One of the most common advantages is the tax exemption commonly referred to as "tax refund." Under certain conditions, exporters may benefit from VAT and SCT exemptions and reclaim the VAT and SCT paid for goods once the export has been completed. In addition, as a general principle, customs duties are not applied to exports. That is, exporters are not required to pay customs duties on exported goods. However, DFIF is still collected during the export process.
The purpose of DFIF is to support the subsidization of agricultural inputs, protect producers from price fluctuations, promote exports, finance export-oriented investments, and serve as a provisional form of export insurance until an official export insurance system is established.
This measure was introduced to address stagnation in exports and aims to enhance competitiveness in foreign markets by paying premiums at various rates for certain goods.
The goods subject to DFIF deductions and the relevant amounts are listed below:
- All types of natural shelled hazelnuts: TL equivalent of 8 cents/kg (as per Official Gazette dated 18/12/1997)
- All types of unshelled hazelnuts: TL equivalent of 4 cents/kg
- All animal hides and skins, including pickled leather but excluding processed leather and sole leather under tariff headings 41.01, 41.02, and 41.03, and chromium leather under 4104.11 and 4104.19 (except split leather): TL equivalent of 50 cents/kg;
- For chromium leather under 4105.10 and 4106.21: TL equivalent of 20% of FOB export value
- Cotton (uncombed or uncarded) under 5201.00: TL equivalent of 0 cents/kg
- Cotton (combed or carded) under 5203.00.00.00: TL equivalent of 0 cents/kg
- Chicken eggs (Gallus domesticus species) under 0407.21.00.00.00: TL equivalent of USD 1.5/kg (as per Official Gazette dated March 25, 2025)
As observed, DFIF deductions are primarily applied to the export of agricultural products, aiming to encourage the export of processed products and discourage the export of raw materials with low added value.
In taxation, a key concept is the moment the customs obligation arises. In the case of DFIF, the event triggering the obligation is the export of the goods subject to deduction.
Exemptions from DFIF deductions are defined in Article 11 of Decree No. 88/13384. These include:
- No DFIF deduction is applied on the export of free samples valued at FOB USD 1,000 or less for goods covered by DFIF.
- For natural hazelnuts exported in packages of up to and including 1,000 grams, a 4 cents/kg (2 cents/kg for unshelled hazelnuts) deduction is applied from the standard DFIF rate.
- No deduction is made for processed liquid hazelnut products in small consumer packages.
- A 4 cents/kg (2 cents/kg for unshelled hazelnuts) deduction is applied for natural hazelnut exports to countries in America, Oceania, the Far East, and African countries without Mediterranean coastlines.
Article 4 of the same Decree addresses the collection authority, stating that DFIF amounts must be collected by intermediary banks or private financial institutions based on the rate in effect on the customs declaration date, regardless of whether export proceeds have been brought into the country. This collection must be completed within the statutory period for repatriating export proceeds (excluding extensions) after the actual export takes place.
Therefore, customs authorities do not collect DFIF deductions. Instead, they require exporters to submit a bank receipt showing that the DFIF payment has been made before the customs declaration is registered. Unless this receipt is provided, customs authorities will not allow the export. An exception applies in hazelnut exports, where a guarantee mechanism is available.
Moreover, DFIF collection is governed not by the provisions of the Customs Law No. 4458, but by the Law No. 6183 on the Collection of Public Receivables.
As for penalties, the provisions of Law No. 2976 on the Regulation of Foreign Trade apply, not the Customs Law. According to Article 4 of this law, those who engage in import, export, or other foreign trade transactions without fulfilling the additional financial obligations imposed by Presidential Decree are subject to a fine equal to twice the unpaid obligation.
Another significant point concerns objections and settlement procedures. Since DFIF deductions are not collected by customs authorities and are governed by Law No. 6183, exporters cannot file an objection or settlement request with the relevant Regional Directorate of Customs and Foreign Trade. Furthermore, DFIF is not included in the list of customs duties eligible for reconciliation as listed in Annex-1 of the Reconciliation Regulation.
NOTE: Exporting companies must submit a bank-stamped receipt showing that the DFIF amount (calculated based on the Central Bank of Turkey's foreign exchange buying rate on the relevant day) has been deposited into the account titled “CBRT DFIF – Premiums Collected from Table Egg Exports.” Only then will the General Secretariat of the Central Anatolian Exporters' Association register the export declaration.
