One chain
A holding owns 40% of the company and a person owns 80% of the holding: 40% × 80% = 32%, above the 25% threshold.
How-to · Ownership
How to find the shareholders of a Turkish company
In a Turkish limited company (Ltd. Şti.) partners and share transfers are registered and published, so ownership can be followed from registry notices. In a joint-stock company (A.Ş.) the founders are published, but later transfers are entered only in the share register. Listed companies disclose threshold changes on KAP; ask for the share register for the current position.
- Table by company type
- Indirect holdings worked out
- Every rule with its article
Last reviewed · Ulawk editorial team
Where to look
Where shareholders appear, by company type.
The words "anonim şirketi" (joint-stock) or "limited şirketi" (limited) in the trade name tell you which source to trust.
| Company type | Where shareholders appear | Watch out |
|---|---|---|
| Limited company (Ltd. Şti.) | Incorporation notice and later share-transfer notices; share register | A transfer is made in writing with notarised signatures and, as a rule, takes effect with general assembly approval (TTK art. 595); managers apply for registration (TTK art. 598). |
| Joint-stock company (A.Ş.) | Articles at incorporation; afterwards the share register | Only persons in the share register count as shareholders (TTK art. 499); transfers are usually not published, so ownership in old notices may be out of date. |
| Single-shareholder A.Ş. | Notice of single-shareholder status | The sole shareholder's name, residence and nationality are registered and published (TTK art. 338). |
| Listed A.Ş. | Shareholding structure and ownership notifications on KAP | Trading on the exchange does not reach the registry; threshold crossings are disclosed on KAP. |
| Company owned by another company | The shareholder company's own records | Continue up the chain through each shareholder company to reach a natural person. |
Method
Ownership in six steps.
Registry notices are the starting point; the share register kept by the company has the last word.
Only a person entered in the share register is a shareholder towards the company.
TTK art. 499(4). Where an A.Ş.'s notices and share register differ, the share register prevails.
Identify the company type
Limited, joint-stock or listed? The table above shows which source is enough.
Read the articles at incorporation
The capital clause lists the shares subscribed by each founder: the starting picture.
Apply transfers and capital changes in order
A limited-company transfer notice may name only the parties to that transfer; update the full distribution using earlier notices. Capital increases and decreases change the shares too.
Follow corporate shareholders
If a shareholder is a company, look at its shareholders as well; multiply the percentages along the chain for the indirect holding.
Identify the beneficial owner
Under Turkish anti-money-laundering rules (MASAK): first a natural person holding more than 25%; failing that, whoever controls by other means; failing that, senior management.
Confirm with documents
Share register, attendance list of the last general assembly and a written declaration from the company.
Worked examples
Indirect holdings, worked out.
Multiply along each chain and add up the routes that lead to the same person.
Two routes
The same person holds 10% directly and 20% through another company: 30% in total.
Below the threshold
If nobody exceeds 25%, move to the control and senior-management tests and say so in the report.
With Ulawk
Ownership with Ulawk
Ulawk extracts shareholders and share movements from the company's notices; every line is tied to its source notice.
Shareholders and share movements
Shareholders, share transfers and capital history as far as the notices disclose them, each change shown against the previous position.
Beneficial owner candidates
Candidates above 25% calculated along the ownership chain; calculated information is labelled separately from what is declared.
Group map and network
The structure around the company through shareholder and officer links.
Stated limits
For a joint-stock company the report says that share transfers are not published.
Why are the current shareholders of an A.Ş. not in the notices?
A transfer of registered shares becomes effective towards the company by entry in the share register and is not registered with the trade registry. Notices show the founders, the sole shareholder of a single-shareholder company and capital transactions.
When does a share transfer in a limited company take effect?
With general assembly approval, unless the articles say otherwise. If the general assembly does not refuse within three months of the request, approval is deemed given (TTK art. 595).
Does a board member have to be a shareholder?
No. A board member of an A.Ş. need not hold shares; in a limited company at least one partner must have management and representation rights (TTK art. 623).
Official sources
- Turkish Commercial Code (TTK, Law 6102)mevzuat.gov.tr↗
- Financial Crimes Investigation Board (MASAK)masak.hmb.gov.tr↗
- Public Disclosure Platform (KAP)kap.org.tr↗
This page is general information, not legal advice.
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