Why Turkish Banks Treat Incoming Wire Transfers as Loans — and How to Prevent It

Opening a business bank account in Turkey and receiving payments into it are two different problems. I covered the account-opening process in detail in Opening a Business Bank Account in Turkey as a Non-Resident. This article focuses on what happens after the account is open: specifically, why a bank might treat a perfectly ordinary commercial payment as a loan, and why an imprecise invoice description can hold up an incoming transfer for weeks.

Why a Bank Classifies an Incoming Transfer as a Loan

The nature of an incoming payment is not determined solely by your own accounting entry. The bank evaluates the SWIFT description, the relationship between sender and recipient, the contract, the invoice, the transfer amount, the currency, the economic purpose of the payment, and the company’s declared business activity — all at once.

The first thing the bank checks is the payment description in the SWIFT message. Under the Central Bank of the Republic of Turkey (TCMB) Capital Movements Circular, banks are required to check whether a description on an incoming transfer suggests the amount is a credit facility. If a commercial payment sent to a Turkish company carries the description “intercompany loan,” the bank may classify the transaction as an intra-group credit rather than a service payment.

When that happens, the bank will typically request: a loan or credit agreement, maturity details, interest rate, repayment schedule, board resolutions, and documentation showing compliance with foreign-currency borrowing conditions. The company later saying “this was not actually a loan” is not sufficient on its own. The bank may then require a correction message from the sending bank and supporting documentation proving the real nature of the transaction.

Is Every Transfer from the Parent Company a Capital Injection?

No.

A payment from a foreign parent or shareholder to a Turkish subsidiary can be a capital contribution, a shareholder or group-company loan, a service fee, a cost recharge, or a customer advance. The nature of the transaction must be determined before the transfer is sent.

For an amount to qualify as capital, it must be consistent with the company’s capital commitment or capital increase documentation. If the money will be repaid at some point, the transaction resembles debt more than equity. If it is sent in exchange for a genuine service, it should be treated as a commercial payment backed by an invoice and a contract.

Vague Descriptions Also Cause Problems

Not every problem starts with the word “loan.” In practice, descriptions like “funding,” “financial support,” “cash support,” “intercompany payment,” “group transfer,” “general expenses,” or “advance” can also fail to explain the real purpose of a payment adequately. These phrases do not automatically mean credit — but they can prompt the bank to request additional documents to determine whether the transfer is a capital injection, a loan, or a commercial transaction.

Under TCMB regulations, banks may request a written declaration from the company for transactions above certain thresholds where the reason for the transfer cannot be determined. In addition, banks may scrutinize unusual transactions regardless of amount, driven by their own MASAK obligations and internal risk policies.

How an Imprecise Invoice Description Delays Payment

An invoice is not just a payment request. It is a tax document that describes the nature of a delivery of goods or services. Generic descriptions like “service fee,” “consultancy,” “general support,” “management fee,” or “professional services” are therefore often insufficient.

The invoice description should, where possible, specify the type of service, the service period, the relevant contract reference, and a project or invoice number. For example:

Software development and technical support services provided under the agreement dated 1 May 2026, covering June 2026.

This description should only be used if the service was actually provided.

What Inconsistencies Prompt a Bank Review?

The invoice and the SWIFT description say different things

If the invoice reads “software development services” and the SWIFT message reads “shareholder loan,” the same transaction has been described in two incompatible ways.

The invoice and the contract do not match

If the contract covers marketing services but the invoice says management consultancy, the bank will have questions about which transaction this payment actually relates to.

The invoice amount and the transfer amount differ

If the invoice is for €50,000 but the payment is €75,000, the difference needs to be explained — whether it is an advance, an expense, a loan, or a separate invoice.

The invoice is addressed to a different group entity

If the paying company and the invoice recipient are different, the relationship between the parties and who the payment is being made on behalf of will need to be explained.

A cost recharge is not documented

If the description uses “reimbursement” or “cost recharge,” supporting expense documents, the allocation method, and an intra-group agreement must be available.

Is Writing “Service Fee” Instead of “Loan” Enough?

No.

For a payment to qualify as a service fee, a service must actually have been provided. The transaction needs to be supported by a service agreement, a detailed invoice, work or delivery reports, email and project records, and a transfer pricing assessment.

Issuing an invoice simply so the bank accepts the payment — when no real service was rendered — creates far greater risk from a tax and record-keeping standpoint. The right approach is not to produce a description the bank will accept easily. It is to determine the true legal and economic nature of the transaction first, then prepare the contract, invoice, SWIFT description, and accounting entry consistently with that nature.

What Happens When the Wrong Description Is Used?

The typical sequence:

1. The money arrives at the Turkish bank but is not credited to the account.
2. The bank reviews the SWIFT description.
3. The company is asked for a contract, invoice, and written explanation.
4. The documents are checked against the transfer description.
5. If necessary, a correction message is requested from the sending bank.
6. The file is escalated to the bank’s foreign exchange or compliance department.
7. The transaction is approved or the money is returned to the sender.

The process can take anywhere from a few business days to several weeks. The delay is usually caused not by where the money came from but by the fact that the transaction has been described differently in different documents.

What Documents to Provide When There Is a Problem

Submit a single, consistent file to the bank. It should include: a cover letter stating the transfer date and SWIFT reference; a company declaration explaining the true nature of the transaction; the signed contract; the correct invoice; service or expense documentation; a letter from the sending company; a correction message from the sending bank if required; and a brief note on the accounting entry for the transaction.

Having different people provide conflicting explanations will extend the process further.

The Pre-Transfer Checklist

Before sending the transfer, confirm that five elements describe the same transaction: the contract, the invoice, the SWIFT description, the board resolution (if applicable), and the accounting entry.

If a genuine service invoice is being paid, the SWIFT description might read:

Payment of invoice TR-2026-045 for software development services provided in June 2026.

Writing only “intercompany transfer” is not enough. That phrase explains that money is moving between group companies — it does not explain why.

A Common Mistake: Editing the Invoice PDF After the Fact

Modifying the PDF of an incorrectly issued invoice and resending it is not the right approach. Depending on whether the invoice was issued as an e-Invoice, e-Archive invoice, or paper invoice, the correct cancellation, objection, or correction procedure must be followed.

The replacement invoice should reflect the actual service, be consistent with the contract, include the service period, and match the bank transfer description.

Conclusion

In cross-border transfers into Turkey, a single word can change the entire processing path. If a commercial payment is mistakenly described as a “loan,” the bank may request a credit agreement, review foreign-currency borrowing conditions, escalate the file to its compliance team, hold the funds temporarily, and — if the documentation is insufficient — return the payment to the sender.

Vague or generic invoice descriptions compound the problem: the contract, the invoice, the bank description, and the accounting entry begin to tell different stories about the same transaction.

The safest approach when sending money from abroad is to determine the true nature of the transaction first — then build the contract, invoice, bank description, and accounting entry around that reality.

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Related reading: Opening a Business Bank Account in Turkey as a Non-Resident covers the account-opening sequence, the compliance file approach, and what to expect at the branch.