A decision to Launch an Investigation on the Economic Unity composed of Alphabet Inc., Google Ireland Limited, Google LLC, Google International LLC and Google Reklamcılık ve[...]

In order to determine whether Google's invoicing practices and commercial practices regarding its advertiser and advertising agency customers under the scope of online advertising services it provides violated article 6 of the Act No. 4054 on the Protection of Competition (the Act No. 4054), it was decided to launch an investigation about Google per article 41 of the same Act.

Online advertising sector has a multilateral structure that enables advertisers to reach their target groups through digital channels. In this system, advertisers and websites, publishers who provide advertisement area in applications and similar digital channels are brought together through various advertising technology services. Thanks to those services, digital advertisement inventory is marketed via software systems and sale and purchase of advertisement areas, especially display advertisements, are largely made through automatic processes.

The advertising activities in the sector are conducted within the framework of the relations established among advertisers, advertising agencies and digital advertisement service providers. While advertisers constitute the party who provide the advertisement demand and budget for the promotion of their products and services, advertising agencies offer strategic and commercial services to advertisers in areas such as planning campaigns, selecting the appropriate digital channels, managing the advertisement budget and reporting the performance results.

The allegations that are the subject of the investigation concerns whether Google carried out discriminative practices by means of invoicing both its advertiser and advertising agency customers through different legal personalities under the scope of its online advertising services. The basis of the relevant examination is the fact that while advertiser and advertising agency customers who are invoiced through Google Ireland are subject to withholding obligation according to Turkish tax legislation, advertiser and advertising agency customers who are invoiced through Türkiye are not subject to this obligation. In this context, whether international invoicing structure and accordingly tax obligations lead to different cost effects in terms of certain undertakings that are under the same classification as well as whether the said practices have the nature of abuse of dominant position under the scope of Article 6 of the Act No. 4054 by means of leading to discriminative results were evaluated with respect to especially advertiser and advertising agency customers, by taking into account the classifications to which they are subject to.

Having discussed the information and documents acquired and observations made in the preliminary inquiry about Google, which started in January 2026, in its meeting on 05.03.2026, the Competition Board considered that the findings were significant and sufficient, and took the decision numbered 26-08/233-M that an investigation shall be opened about Google. During the investigation process, the criteria according to which Google classifies its advertiser and advertising agency customers, whether this classification is objective, how the classification in question is reflected to invoicing and what kind of cost effects it creates on undertakings as well as whether Google carries out other discriminative practices on the basis of the classification to which it subjects its advertiser and advertising agency customers will be explored in detail.