The starting point of this article is that, in recent times, many companies have been asked by the businesses they work with — whether as buyers or sellers — for the "KURGAN Documents". In fact, no such document set exists; it is generally known among traders under the label of MASAK (Financial Crimes Investigation Board) Documents. While the Revenue Administration keeps pace with technology and leverages big data through the applications it has developed and deployed in recent years, it is also sending a very important message to the market: "institutionalize your business".

First, let us go over the applications developed by the Revenue Administration:
E-VİZ: Electronic Data Submission System
VDK RAS: Risk Analysis System
MBR: Taxpayer Information Report
VEDEBİS: Tax Offices Audit Information System
SARP: Fraudulent Document Risk Analysis
DERİN: Ledger Risk Examination System
RADAR: Risk Analysis, Evaluation and Research
KURGAN: Entity-Supervised Analysis System
VEDAS: Tax Audit and Analysis System
MEVA: Spatial Data Analysis System

The one we hear about most, and the most talked-about application of 2025, has been KURGAN. In general terms, the Tax Inspection Board has begun auditing more comprehensively those companies flagged by its internal alerts and critical checkpoints. Unlike in previous years, when scrutiny was largely limited to Fraudulent or Misleading Documents (SMİYB), they can now trace businesses' financial movements step by step through electronic documents and data. E-invoice systems, the e-ledger structure, bank transactions and e-receipt systems are examined in far greater depth; in doing so, they employ the fastest data-processing tools available, such as artificial intelligence, and where an inconsistency is detected, the INVITATION TO PROVIDE AN EXPLANATION mechanism is swiftly triggered.

So let us return to the main question: What exactly is the Tax Authority telling us? It is trying to say "Institutionalize your business," and it is stating this directly: "You know how, when you start working with large companies, they ask you for contracts, supporting documents, filing, supplier qualification certificates… The Revenue Administration's (GİB) message is much the same: 'You, too, should request these from your suppliers. Think like a prudent merchant.'" Because when a transaction is questioned (especially where there is a risk of fraudulent/misleading documents), the burden of proof can largely rest with the taxpayer. If the explanation is weak, the matter can lead to penalties and tax assessments following an examination, and may subsequently be taken to court — with consequences that grow heavier in terms of both time and cost.

At the heart of audit risk lies the following distinction: the risk of a fraudulent document — documenting a transaction that never actually took place; and the risk of a misleading document as to its content — where a transaction appears to exist, but there are inconsistencies in content/quantity/goods-services, or contradictions with the actual facts. For example, if there is an invoice for goods that are not in the warehouse and the goods do not physically exist, the risk grows enormously. In such cases, consequences such as the rejection of the VAT deduction or the reclassification of the expense as a non-deductible expense (KKEG) can come into play. In short: "having an invoice" is not enough on its own. The actual flow and process (goods/services/transport/payment) must be supported by documentation.

What do "KURGAN Documents" mean in practice?

The content requested under the name of KURGAN documents actually resembles the "personnel-file logic" that corporate companies have applied to their suppliers for years.

The most frequently requested documents: Contracts, certificate of activity, the company's past Trade Registry Gazettes / shareholding structure, a capacity report if the company is a manufacturer and a yield report if available, dispatch notes / transport documents for the movement of goods, barcode/QR-code images if delivery was made via courier/freight depot, a vehicle route list if required (which may be requested stamped and signed), and in some requests, attachments such as Findeks reports (which may not be mandatory in every case).

But the logic is always the same: "Can this company actually perform this work? Does the flow of goods/services really exist?"

Once the Revenue Administration has a clear answer to this question, it proceeds to the stage of Assessment, Accrual and Collection.

Let us also talk a little about the VEDAS system. We could call it one of the main arteries operating in connection with KURGAN downstream.

The core headings here: E-ledger and e-invoice analyses, revenue and cost analyses, valuation transactions and accounts, depreciation and inflation adjustment procedures, notional interest (adat) checks, shareholder current account checks, duplicate value checks, document serial number checks, reverse account balance checks, cross-checks between buyers and sellers, and checks of book inventory against revenue accounts are the main headings of VEDAS.

Simply giving priority to these balances in the balance sheet and trial balance — the core data reports — with the headings above in mind will help ensure accurate reporting.

For full coverage of the topic, you can watch or listen to my video via the link below: