Invoicing agencies and tour operators: net rates, VAT and accommodation tax

When you issue a hotel invoice to travel agency Türkiye partners, the contract type decides who the buyer is. Under a net contract the hotel sells to the agency and invoices it the net price. Under a commission contract the guest is the hotel's customer and the agency invoices the hotel for commission. Accommodation tax is computed on the hotel's price excluding VAT and appears on the agency invoice only when the agency included it in the guest's price.

The voucher says net, per room per night. The agency's invoice arrives with a different total, no accommodation tax line and a rooming list attached. Someone has to decide what the hotel's own invoice should have said, to whom, and on what base. After reading this you will be able to tell a net contract from a commission contract, build the hotel invoice to a travel agency in Türkiye correctly, place the accommodation tax on the right document, and know why a foreign operator's address changes less than expected.

Net contract or commission contract: who is the buyer?#

The contract type decides who the hotel's customer is, and that single fact decides who receives the invoice and what appears on it.

Under a net contract the hotel sells the room to the agency at an agreed net rate, the agency resells at its own price, and the hotel's customer is the agency. Under a commission contract the guest is the hotel's customer, the hotel's contract rate is the price the guest pays, and the agency is paid for bringing the booking. This is where the error begins: a hotel that invoices the guest under a net contract has invoiced the wrong buyer, whatever the amount.

The practical test is who sets the price the guest pays and who carries the risk if the room goes unsold. If the hotel sets the guest price and the agency is paid a percentage, it is a commission arrangement. Read the contract and the voucher for the words net, commission, on behalf of, allotment and guarantee. The wording of the agreement, not the invoice, decides the treatment.

Mixed relationships exist: net for groups and commission for individual bookings, or one basis for one season and another for the next. Treat each booking on its own terms. The agency definition also matters for the accommodation tax rules, so keep the agency's certificate on file with the contract, as covered in agreements with travel agencies in Türkiye.

What does the hotel's invoice show under a net rate?#

It shows the hotel's own net price for the accommodation, invoiced to the agency, and nothing about the price the agency charged the guest.

The net rate is the hotel's selling price, not a discounted gross. The agency's markup is the agency's revenue and never appears on the hotel's invoice. Invoice the agency in its own name with its own tax details, because the agency is the buyer and declares the purchase on its own return.

The accommodation tax base is the amount received for the service excluding VAT, and customary trade discounts shown separately on the invoice may be deducted from that base. The Communiqué's own example: a hotel sells rooms to an agency for TRY 20,000 excluding VAT and the agency resells them to a tourist group for TRY 22,000; the hotel computes the tax on TRY 20,000, per the Accommodation Tax Implementation General Communiqué (Resmî Gazete, 14 December 2022, No. 32043) (opens in a new tab). The second figure is context, not a rate to copy. Do not restructure the invoice to shrink the base; the base follows the price the hotel actually charged.

An advance from the agency is not the invoice. The taxable event is still the service, so the invoice follows the stay, not the payment; the mechanics of early payments are covered in tour operator advance payments. If the agency pays in foreign currency, which rate and which day applies is a question for your accountant, not a guess for the reservations team.

What does the invoice look like under a commission contract?#

The hotel invoices the guest at the contract rate, and the agency invoices the hotel for its commission as consideration for its own service.

There are two invoices, two taxpayers and two different services: accommodation from the hotel, intermediation from the agency. The hotel's invoice to the guest carries the full contract rate. The commission is a cost for the hotel, not a reduction of the guest's bill, unless the contract says the guest pays net of commission.

The agency's commission invoice is the agency's own VAT question, including its rate. The hotel's check is simpler: does the commission invoice match the contract percentage and the bookings it names. Where the agency collects from the guest and remits the balance, the hotel's revenue is still the full amount and the commission is an expense; the cash movement does not change what the invoice should say.

File the commission invoice with the booking so the voucher, the guest invoice and the commission invoice reconcile without a search.

Does the agency invoice have to show accommodation tax?#

Not always. It depends on whether the agency included the accommodation tax in the price it charged the guest, and whether it can prove and document that to the hotel.

No taxable event arises when a room is sold to an agency as defined in the Travel Agencies Regulation, and none arises when the agency resells it. Whether a stay is sold through an agency or directly, the taxable event is the provision of the service to the guest, as the Accommodation Tax Implementation General Communiqué (Resmî Gazete, 14 December 2022) (opens in a new tab) states.

From there the Communiqué gives two paths. If the agency sold the stay with the tax included in the customer's price and documents this to the facility, the facility shows the accommodation tax on the invoice it issues to the agency for the stay. In the Communiqué's examples that invoice carries the guests' details, for example name and surname. If the agency did not include the tax in its price, the hotel shows the tax on a separate invoice issued to the guest after the service, containing only the accommodation tax; the separate lines and receipts are covered in accommodation tax on hotel invoices.

The rate needs care. The Communiqué's examples use the statutory 2%. Presidential Decision No. 11263 (Resmî Gazete, 1 May 2026, No. 33240, in force on publication) applies 1% until 31 December 2026 inclusive. Check the rate in force on the service date, not the invoice date.

The Communiqué does not prescribe the form of the agency's confirmation, so agree one in the contract: a written statement per booking, kept with the voucher. The Communiqué is the binding text here, so quote it rather than a secondary summary.

How does a foreign tour operator change the VAT treatment?#

Less than most hotels expect. The test is where the service is performed and where it is benefited from, not where the buyer is registered.

Place of supply: under Article 6(b) of VAT Law No. 3065, a service takes place in Türkiye when it is performed in Türkiye or benefited from in Türkiye. The export of services rule in Articles 11(1)(a) and 12(2) needs both conditions: performed for a customer abroad, and benefited from abroad. A customer abroad is defined by residence, workplace, legal seat and business centre, or by an independent foreign branch of a Turkish firm.

Evidence matters. The first condition is evidenced by an invoice issued in the foreign customer's name. Benefited from abroad means the service relates to the customer's business abroad and has no link with its activities in Türkiye, according to Section II/A-2 of the VAT General Implementation Communiqué (mevzuat.gov.tr, consolidated text) (opens in a new tab).

That section's Example 3 is a Turkish travel agency serving a tourist group sent by a foreign agency. The Turkish agency's own service, the amount left after the group's costs in Türkiye, is exempt. But the accommodation and food the group receives in Türkiye are benefited from in Türkiye and are subject to VAT. The exempt and taxable amounts may be shown separately on one invoice or invoiced separately.

For a hotel, the guest sleeps in Türkiye and the service is consumed in Türkiye, so the benefit test points at Türkiye. A foreign invoicing address does not turn the room into an export. Do not zero-rate on the strength of a foreign address; take the specific contract and voucher to your accountant and ask about that booking. Identity and currency fields for foreign guests are covered separately in invoicing foreign guests in Türkiye.

How do you check the invoice against the voucher and the rooming list?#

Three documents have to agree on the same facts: the voucher fixes the terms, the rooming list fixes the people, and the invoice has to match both.

The voucher should state the contract type, the rate basis (per room per night or per person), the meal plan, the service dates, what is included, and who pays what on site. The rooming list carries names, nights and room types. Where the accommodation tax goes on the invoice to the agency, that invoice carries guest details, so the rooming list is the source for them.

Dates matter for the rate. The accommodation tax rate follows the service date. A stay that crosses 31 December 2026 moves from the 1% rate to the statutory rate, so agree with your accountant how the invoice splits it before the first such booking.

Check the arithmetic: base multiplied by rate equals the tax line, and the base is the hotel's own price excluding VAT. Any discount deducted must be shown separately on the invoice. Keep the paper trail together: the agency's written confirmation, the commission invoice if any, the voucher, the rooming list and the invoice, in one file per booking. The rooming list and the daily guest list are different documents serving different duties; the latter is covered in the daily guest list under the Tax Procedure Law. Keep them consistent rather than treating one as a copy of the other.

What should you settle in the contract and with your accountant?#

Put the invoice mechanics in the contract before the season, and take specific bookings to your accountant with the documents rather than asking general questions.

In the contract, state in words whether the arrangement is net or commission, and who invoices whom for the room. State whether the agency's price to the guest includes the accommodation tax, and what written confirmation the agency will give per booking. State the currency, the rate basis, who bears a rate change mid-season, and which side issues which document. Keep the agency's certificate and the definition it relies on with the signed agreement.

With your accountant, bring the voucher, the rooming list, the agency's confirmation and the draft invoice, and ask for the treatment of that booking. Ask the foreign operator case separately, because whether a service is benefited from abroad is a question about facts, not about the buyer's address. Confirm dates, rates and any penalties for your own case with your accountant or legal adviser; this article describes the mechanism, not your file.

What to do next#

Take one recent agency booking and assemble the four documents: voucher, rooming list, the agency's written confirmation and the invoice. Check that the accommodation tax sits on the right document, on the hotel's own price excluding VAT, at the rate in force on the service date. Then fix the contract wording before the next season, so the answer is settled before the invoice is written.