What is KURGAN (Foundation Supervised Analysis System)?

1. Introduction: A New Era in Tax Auditing – Why is KURGAN Important?

The Corporate Supervisory Analysis System (KURGAN) is a risk analysis and audit infrastructure developed by the Tax Audit Board of the Ministry of Treasury and Finance, based on big data and artificial intelligence . While not directly defined by a specific law in tax legislation, its framework is established by the "Strategy for Combating Counterfeit Documents and KURGAN Guide," published on October 1, 2025. KURGAN simultaneously analyzes information from e-invoices, e-ledgers, bank transactions, customs records, declaration data, and many other sources, generating risk scores for transactions . The aim is to detect counterfeit documents (fictitious invoices) and unregistered transactions at an early stage, before many years have passed since the transaction .

2. What is the KURGAN Foundation Supervised Analysis System?

2.1. Brief Description

In its simplest terms , KURGAN is an AI-powered, data-driven tax risk analysis system developed by the Tax Audit Board .

System;

It collects all financial transactions of taxpayers electronically.
We continuously perform risk analysis based on this data ,
For transactions it deems risky, KURGAN informs the taxpayer through official notices
It can trigger tax audits and other inspection processes when necessary.

Therefore, KURGAN is not a "type of examination" in the classical sense; an intelligent filter and early warning mechanism that operates before the examination itself.

2.2. The Meaning of the Phrase "Organization Supervised"

The phrase "Organization Supervised" in the name is no coincidence. Official guidelines and strategy texts clearly state that KURGAN is designed to monitor its clients from the moment the company is established

What does this mean?

Not just companies that have been in operation for years,
Newly established "shell companies," with weak capital, frequent address/partner changes, and generally opened for the purpose of forging documents, also
fall under the system's radar from the very beginning.

In other words, KURGAN establishes a process monitoring model that tracks the company's life cycle "from the day it was founded"

2.3. What Purposes Does the System Serve?

The objectives of the KURGAN Institutional Supervisory Analysis System can be summarized under the following main headings:

Early detection in the fight against counterfeit documents
tax audit resources towards risky taxpayers and transactions,
Reducing tax evasion and fraud by monitoring it in real time,
Increasing digitalization and transparency while doing all of this

In conclusion, KURGAN a "radar system", and "an airplane receiving a warning on its screen" .

2.4. Structure of the KURGAN:

It is a tax risk analysis system that tracks the taxpayer from the moment of establishment (day zero)
the Ministry of Treasury and Finance's big data platform ; it analyzes billions of records, including real-time/daily data such as e-documents.
Transaction risk is measured using numerous criteria, including the authenticity of transactions, the consistency of their amount and nature with the actual situation, and transactions with related parties that are inconsistent with comparable transactions .
The aim is to detect the forged document as quickly as possible , enabling current audits and on-site verification.

3. The Legal and Institutional Background of KURGAN

3.1. Strategy for Combating Forged Documents

The Ministry of Treasury and Finance declared October 1, 2025, a turning point in terms of the "Strategy to Combat Counterfeit Documents," and activated KURGAN as the most critical part of this strategy

This strategy:

Those who forge or use documents will be
action not only through standard tax audits,
risk analysis, electronic monitoring, rapid inspections, and physical inventory .

In this context, KURGAN the brain of the strategy .

3.2. Debates on Article 140/A of the Tax Procedure Law and the Aspect of Tax Crime

The proposed amendment to the Tax Procedure Law, Article 140/A, aims to separate tax audits from tax crime investigations and to utilize criminal procedural tools for tax crimes.

This means:

The investigation procedure for detecting tax evasion is separate
In cases such as tax evasion or document forgery, criminal investigations will be conducted separately.
The risk signals coming from KURGAN trigger a criminal investigation .

Therefore, KURGAN is not only an "administrative control tool" but also an intelligence filter connected to the tax crime ecosystem

3.3. Information Request Letters within the Scope of Articles 148, 149 and 355 of the Tax Procedure Law

The KURGAN inscriptions are technically classified as "requests for information." The tax administration can request information and documents from taxpayers under Articles 148 and 149 of the Tax Procedure Law; failure to comply with this obligation may result in a special irregularity penalty under Article 355 of the Tax Procedure Law .

Because:

The KURGAN inscription is not a penalty notice, but..
Failing to respond at all, or not taking it seriously, may constitute a breach of an obligation that is directly subject to sanctions.

4. How does the KURGAN Foundation Supervised Analysis System work?

4.1. Data Sources Collected

KURGAN's strength its ability to combine very different data sources into a single pool . Official documents and career guides state that the system evaluates the following data together:

e-Invoice and e-Archive invoice records,
e-Ledger data,
Tax returns (VAT, income tax, corporate tax, withholding tax, etc.),
POS and bank transactions,
Customs and import-export data,
Land registry, social security, and in some cases, other public administration data.

These data are analyzed not individually, but in an interconnected manner . For example, an invoice is viewed alongside inventory records, bank payments, and the supplier's customer history.

4.2. Artificial Intelligence and Risk Scoring Logic

KURGAN Foundation Supervised Analysis System works with this data using artificial intelligence and machine learning techniques

The system generates a risk score for each taxpayer and transaction, taking into account indicators such as the following:

Exceptionally high or low profit margins compared to the industry average ,
New companies that quickly started issuing invoices for very high amounts ,
Irrational discrepancies between purchase and sale transactions, inventory, and bank movements
The existence of extensive transactional relationships with individuals previously identified as forgers of documents ,
Frequent repetition of address, partnership structure, and accountant changes

These types of signals don't necessarily mean a crime in themselves; however, in the eyes of the system, they signify "priority for investigation."

4.3. Integration with VIS (Tax Intelligence System)

KURGAN operates integrated with the Tax Intelligence System (VIS) , established in 2024. VIS stores data from previous fraud investigations, audit reports, and audit experience in a graphic (network) based structure. VIS is a pattern network (graphic database) showing individuals, events, and actions related to fraud; it has no direct impact on the taxpayer and is a closed system.

A KURGAN is:

Fraud networks registered with VIS,
These networks include companies, interpersonal relationships,
What kind of pattern has formed over time?

It is used for risk analysis. Thus, instead of just looking at a single invoice, organized fraud can be detected using network analysis logic

4.4. KURGAN Inscriptions and the Early Warning Logic

The most noticeable outcome of the system for the taxpayer is the "KURGAN inscriptions." These inscriptions are:

It usually arrives via e-notification
It requests additional explanations and documents regarding specific periods and transactions
It gives a specific time frame for a response.

"Instead of initiating the investigation 3-4 years later, warn the taxpayer as soon as a risk signal arises, and give them the opportunity to correct any mistakes they may have made."

Therefore, the KURGAN Institutional Supervisory Analysis System is positioned not only as a tool for punishment, but also as a tool for "early warning and compliance encouragement."

4.5. Impact on Collateral and Reporting Processes

In official strategy texts, the KURGAN findings are mentioned as a future:

In collateral applications,
In the automatic drafting of review reports ,
In prioritizing files

It is stated that the system will not only show which taxpayers are at risk, but will also be decisive in determining "how much collateral should be requested from this taxpayer, and which case should be handled first."

5. KURGAN Foundation Supervised Analysis System: Who and What is it Pursuing?

5.1. Which Taxpayers Are Under Closer Scrutiny?

KURGAN is theoretically a system that covers all taxpayers. However, in practice, some groups a higher risk profile :

Companies that use e-invoices and e-archives extensively,
Exporters and construction companies are frequently involved in VAT refund processes
Companies associated with those who have been found to have forged documents or unregistered transactions in the past,
Companies that generate high turnover in a short period of time and frequently change addresses/partners.

It can be assumed that KURGAN conducts more frequent and detailed scans for these companies .

5.2. Examples of Risky Transactions and Sectors

As part of its strategy to combat forged documents, KURGAN pays particular attention to the following areas:

High-amount VAT refund requests,
Sectors with a historically high risk of forged documents, such as fuel, scrap metal, and textiles,
Construction and similar sectors where the use of informal labor is common,
Businesses that primarily handle cash transactions and have a low level of receipt/invoice issuance.

This doesn't mean other sectors are comfortable; it's just that the priority radar zone .

5.3. Behavioral Risk Indicators

The system doesn't just look at numbers and figures; certain behavioral patterns are also considered as risk indicators.

Numerous companies that appear to be linked through the same accountant,
Changing business addresses frequently,
The fact that the partners opened and closed many companies in a short period of time,
Submitting amendment declarations too frequently,
Unusually high cash flow relative to turnover.

These indicators may be reflected as additional risk scores in the KURGAN Corporate Supervisory Analysis System algorithms

6. What to do step-by-step when the KURGAN inscription is found?

After the KURGAN system was implemented, the first question that came to mind for many taxpayers and professionals was:
"What should I do if I receive a KURGAN notice?"

6.1. Read the text carefully and calmly

The first step is very simple but crucial:

The date and number of the document ,
Which type and period of tax it relates to
specific transaction, invoice, supplier, or customer information is requested.

Most Kurgan inscriptions don't say "describe all your activities";
they focus on specific risky groups.

6.2. Review Accounting and Financial Records

In the second stage, regarding the topics raised in the text:

e-Invoice and e-archive records,
Relevant bank statements,
Delivery notes, transportation documents,
Stock records and inventory counts,
Contracts and technical specifications

It should be checked in detail.

The goal here is to understand internally where the "risk signal" detected by the system is originating.

6.3. Evaluate the possibility of correcting any errors or omissions

If this internal review includes:

False statement,
Incomplete record,
A forgotten bill,
Stock or bank discrepancy

If obvious errors like these are identified, a statement of correction may be issued along with a response to the KURGAN article.

This does not eliminate the penalty in all cases; however:

It is a gesture of goodwill on the part of the administration
It enables early rectification of tax losses
This can put them in a more advantageous position during the sentencing and investigation process.

6.4. Don't Miss the Time Limit, Don't Give Blank Answers

Documents sent within the scope of the KURGAN Establishment Supervised Analysis System are binding in terms of timeliness, in accordance with Article 355 of the Tax Procedure Law.

Failure to respond within the specified time frame,
Unnecessarily generic, "copy-paste" style, empty answers,
Failure to submit the requested documents and information

This could lead to a special penalty for irregularities.

Therefore, the answer is definitely:

Based on concrete data,
Supported by documents,
It should be prepared with professional advice if necessary.

6.5. Get Expert Support

This is especially true when dealing with high-value transactions, complex VAT refund processes, or suppliers with a history of fraudulent documentation

Certified Public Accountant report,
a lawyer experienced in tax law ,
Internal auditor's or independent auditor's report

This can strengthen the response to the question about the KURGAN inscription.

7. Adaptation Strategies for Businesses During the Kurgan Period

KURGAN's Corporate Supervisory Analysis System is essentially a "restructuring alert" .

7.1. Strengthen Data and Document Organization

Now:

Disorganized lists kept in Excel,
Loss of paper delivery notes,
Bank transactions and bills exist in a separate universe

The burial mound became an extremely heavy load to carry

Businesses:

ERP and accounting software,
e-invoicing and bank integrations,
Inventory tracking and warehouse management

It needs to function as a single, unified system

7.2. The “KURGAN Filter” in Supplier and Customer Selection

In this new era, the mentality of "let's buy from whoever offers the lowest price" poses a serious risk.

Businesses:

The tax registration status of supplier companies,
Individuals who frequently open and close companies, and often change their addresses and ownership structures,
Networks known as "risky" within the industry

You should put it on your radar from the very beginning . Otherwise, the risks associated with your supplier may also be reflected in your tax profile through the KURGAN Corporate Audit Analysis System .

7.3. Internal Audit and Risk Management

Especially for medium and large-sized companies:

KURGAN risks should be a separate section in the annual internal audit plans .
Inventory counts should be done regularly
Intra-group transactions and transfer pricing reports should be kept up-to-date
VAT refund applications should be prepared with a thorough risk analysis from start to finish.

These steps improve the alignment between the data the algorithm will be looking at and the company's internal picture

7.4. Employee and Manager Awareness

Purchasing, sales, and finance teams:

What is the risk of forged documents?
What does the KURGAN inscription mean?
What are the consequences of selling without invoices for the company?

Training on this matter is essential. Otherwise, minor violations committed without the administration's knowledge large red warnings .

8. KURGAN from the Perspective of Financial Advisors and Certified Public Accountants

8.1. A New Era in Customer Relations

KURGAN's Supervised Analysis System is significantly transforming the role of financial advisors and certified public accountants. Now, the professional:

Not just the person who prepares the declaration,
a consultant who conducts risk analysis, reads KURGAN's writings, and devises a response strategy .

Therefore, pricing, contracts, and service scopes will need to be revised accordingly.

8.2. Creating Your Own “Mini Kurgan” Inside the Office

Many Certified Public Accountant (CPA) and Chartered Accountant (CA) offices categorize their clients as follows:

To its sector,
Trading volume,
Past tax risks

classify them accordingly and create their own risk scale .

This is important for the following reasons:

More office time is being devoted to risky files,
Preventive measures should be taken with taxpayers who are at high risk of obtaining KURGAN inscriptions .
Making the workload more manageable.

8.3. New Service Areas: KURGAN Adaptation Consulting

A new market is emerging along with the KURGAN:

KURGAN adaptation projects,
Consultancy in preparing a response to the KURGAN inscription
Internal control and process design,
Digital accounting and data integrity projects.

For professionals, these areas long-term consulting relationships .

9. Advantages, Risks, and Criticisms of Kurgan

9.1. Advantages from the Tax Administration's Perspective

KURGAN Corporate Supervisory Analysis System from the perspective of the Tax Audit Board:

Efficient use of audit resources,
Rapid and targeted intervention in the fight against forged documents ,
The fight against the informal economy a digital backbone .
Compliance with international transparency standards

It brings significant benefits such as these.

9.2. Potential Advantages for Honest Taxpayers

KURGAN for honest taxpayers:

This will enable faster detection of those who forge documents and operate illegally, leading to unfair competition
Instead of lengthy and tedious investigations spanning many years, more targeted and reasoned audits,
For firms relying on their own records, this could represent a less uncertain environment in the medium to long term

9.3. Potential Risks and Discussion Points

On the other hand, there are also issues that could spark controversy during the implementation phase:

Algorithm transparency: The weighting of each criterion is often invisible to taxpayers.
False positive risks: Even a completely honest taxpayer can receive a high risk score due to certain patterns.
Data quality: Bank, e-invoicing, inventory system, or ERP errors can create the illusion of a risk that doesn't actually exist.
Privacy and data security: Gathering such a large amount of data in a single system is also of particular importance from a cybersecurity perspective.

Therefore, the KURGAN Corporate Supervisory Analysis System be closely monitored and improved as needed .

10. Frequently Asked Questions (FAQ)

10.1. Does the KURGAN system automatically impose tax penalties?

No. KURGAN is not a penalty mechanism, but a risk analysis and early warning system.
In the initial stage, it only generates information requests and warnings for transactions deemed risky. However, the findings that emerge during this process may lay the groundwork for future investigations and penalty procedures.

10.2. If I receive a KURGAN inscription, will it definitely be subject to examination?

No. The KURGAN inscription does not mean "an investigation has been launched against you." It should be interpreted as "we have received a risk signal, please provide an explanation." If there is no response, or if the response is not convincing, the likelihood of an investigation increases.

10.3. Will KURGAN only be used for fake invoice files?

No. While its primary focus is combating document forgery, official documents clearly state that KURGAN a comprehensive tax risk analysis tool . This includes VAT, corporate tax, undeclared labor, and other high-risk areas.

10.4. Does the KURGAN Establishment Supervised Analysis System cover all taxpayers?

Yes, the system infrastructure has been developed to cover all taxpayers. However, in practice, prioritization will be based on criteria such as sector, transaction volume, and past risk history.

If I give a proper answer to question 10.5. KURGAN, will the problem be completely solved?

Each case is evaluated on its own merits. A proper, documented, and consistent response:

It reduces the risk of special penalties for irregularities
It can reduce the likelihood of an investigation
It is a gesture of goodwill on the part of the administration.

However, if there is a significant tax loss or a connection to fraudulent documentation, simply answering the question may not eliminate all risks.

10.6. What is the nature of the letters sent to taxpayers?

KURGAN letters are information requests written based on Article 148 of the Tax Procedure Law No. 213. These letters are in the nature of counter-examinations. The responses to these letters are used as input for the risk analysis system. Taxpayers are asked about actions that are not easily or readily detectable through electronic and digital data. For example, whether documents related to risky transactions have been recorded in accounting records, included in declarations, or subsequently removed from records by submitting an amended declaration are among the topics on which information is requested from the taxpayer. This information is referred to as reconciliation risks that the system cannot identify. KURGAN letters are not audits themselves, but rather a harbinger of a potential audit.

11. Conclusion: Learning to Live with KURGAN

KURGAN Corporate Supervisory Analysis Systemmarks a new milestone in the digitalization of tax auditing in Turkey.

In this new era:

Record keeping, data integrity, and supplier selection for businesses ,
Risk analysis and compliance consulting for financial advisors .
Targeted and rapid audits for tax administration.

They are now indispensable elements.

In short,
"escaping the kurgan" is impossible; "working in harmony with the kurgan" is mandatory.

For this harmony:

Strong accounting and ERP infrastructure,
Regular internal audits and risk management,
A conscious supply chain policy,
Professional financial and legal advice

It is no longer a choice, but a natural part of daily working practices .

fraud, tax penalties, tax law