What Is Exemption Code 351, and When Is It Used?
Last checked against regulations: September 29, 2026
Short answer
Exemption code 351 means "VAT - Other Non-Exempt" and is not a real exemption. It is used with the SATIS type when a transaction is not exempt but still needs a zero-VAT invoice. For genuine exemptions such as exports, you choose a 3xx/2xx code and the ISTISNA type instead.
Contents
Exemption code 351 appears in the UBL-TR code list as "KDV - İstisna Olmayan Diğer" (VAT - Other Non-Exempt) and, despite its name, is not a VAT (KDV) exemption. It exists for cases where no VAT is calculated but the transaction does not fall under any of the exempt transaction codes on VAT Return No. 1, and it is used on invoices of the SATIS type. For a genuine exemption, such as an export, you choose the relevant 3xx or 2xx code and the ISTISNA type, not 351.
When is code 351 used?
According to the description in the code list of the Turkish Revenue Administration (GİB), 351 is for cases that are not exempt but still require a zero-VAT invoice. To use the code correctly, three conditions must all be met:
- The law contains no exemption provision for the transaction.
- Even so, the VAT amount on the invoice must be zero.
- The transaction does not correspond to any of the exempt transaction codes on VAT Return No. 1.
Because 0% is not a VAT rate, every zero-VAT line requires a reason code; 351 is the code you choose when the reason is not an "exemption." Whether a transaction falls within this scope can be open to interpretation, so confirm with your certified public accountant (mali müşavir) the first time you use it.
The difference between exemption code 351 and real exemption codes
| 351 | 3xx and 2xx exemption codes | |
|---|---|---|
| Meaning | Non-exempt, zero-VAT transaction | Full or partial exemption granted by law |
| Invoice type | SATIS | ISTISNA (also IADE, SGK, YTBISTISNA, YTBIADE) |
| Use with ISTISNA type | Invalid | Valid |
| Example | Zero-VAT transaction not based on an exemption article | 301 export of goods, 322 suitcase trade |
You can find an annotated list of all 3xx and 2xx codes in our e-invoice (e-Fatura) exemption codes guide.
Common mistakes marketplace sellers make with 351
Issuing an international order with 351. If you shipped goods to a customer abroad through Amazon or your own website, this is an export of goods; the correct code is 301 (or 338 if you are the manufacturer), and the invoice type is ISTISNA. An export invoice issued with 351 does not appear as an exemption on the tax return.
Choosing 351 to zero out VAT. In an ordinary sale to a customer in Türkiye, VAT is calculated at the product's rate. 351 is not a "VAT-free sale" button; invoicing a sale with no exemption basis at zero VAT creates a risk of under-reporting.
Confusing 351 with 555. Both codes are for "non-exempt" cases, but they work in exactly opposite ways: on a line with 351, VAT is zero, while on a line with 555, VAT is calculated and cannot be zero. We explain when 555 is chosen in our what is code 555 article.
Frequently asked questions
Can code 351 be used with the ISTISNA type?
No. Since 351 is for non-exempt transactions, it is used with the SATIS type; the ISTISNA type is for 3xx and 2xx codes.
Are 351 and 555 the same thing?
No. On a line with 351, VAT is zero; on a line with 555, VAT is calculated and cannot be zero, but no rate check based on the activity code is applied.
Resources
#code 351#exemption code#zero VAT#e-invoice
Kafatura Editorial Team
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This article is translated from the Turkish original; regulatory references apply to Türkiye. Read the Turkish original →
