LEGAL REQUIREMENT
According to the current regulations, the corporations which make export of merchandise and which do not have permission to issue e-Archive invoice, shall issue the export invoices in paper form and store them. The corporations which have permission to issue e-Archive invoice shall issue the export invoices electronically (within the scope of e-Archive permission) and print them on plain, white paper in order to be used in Customs procedures. Along with Tax Procedure Law General Circular No.:461 (the “Circular”)which was published in the Official Gazette dated 25.12.2015, the corporations which are obliged to use e-invoice starting from 01.01.2017, whether they have e-Archive permission or not, shall issue the export/accompanied goods export invoices as e-invoice.
Please visit http://www.resmigazete.gov.tr/eskiler/2015/12/20151225-17.htm for legal regularization.

UNDER THE NEW REGULATION
E-INVOICE PROCESS
- The corporations, which make export and which are obliged to use e-invoice, have to issue e-invoice for their exports within the legal scope.
- Export e-invoices shall be issued either by a software adapted to the new regulation or by a service provider or by the current versions of software which can conduct direct integration with Revenue Administration.
- It shall be stated in the technical context (ubl-tr xml) that export e-invoice data is specifically issued within the scope of export and the recipient information must be defined as Ministry of Customs and Trade. Also, the recipient information shall be defined in the new fields marked in the technical guide document of Revenue Administration.
E-INVOICE ISSUING APPLICATIONS FOR EXPORT
The corporations can use either Revenue Administration portal method or Service Provider method or direct integration to Revenue Administration method for e-invoice. However, because of Revenue Administration portal is not going to support export invoice feature, the corporations which make export shall benefit from a Service Provider or use the export adapted versions (which will be prepared up-to-date) of the applications in the ERP packages.
ISSUING E-INVOICE IN FOREIGN LANGUAGE (ENGLISH)
In export process, the invoices prepared in a foreign language (English) are being used in self Customs affairs of the recipient corporations. New regulation did not bring an additional requirement for these invoices. The corporations will continue to issue these invoices with different language contents and different images and transmit them to the recipient corporations via same method (e-mail, fax etc.). The significant fields such as definition of the product in the foreign language, HS code, currency information, amount, price, type of delivery and type of payment can be added to this type of invoices based on the demands of the recipient.
There may be a need to add additional information to e-invoice display feature in pro forma/real invoices which will be transmitted to Customs zone. Under this condition, e-invoice xslt (display information) and ubl-tr xml (context information) can be changed and additional fields can be added to export invoices as a matter of Customs necessity.
EXPORT INVOICES ISSUED AS SERVICE INVOICES
There will be no e-invoice obligation in service invoices or price difference invoices (apart from export/accompanied goods export invoices). Export invoices within this scope will be issued as e-Archive invoice if the corporation is using e-Archive invoice. Otherwise, if the corporation is not using e-Archive invoice, the export invoices will continue to be issued as paper invoice.