Pasifik Holding: TRY 39.7 billion on the books, TRY 6.3 billion on the market

The record

A social-media claim about capital growth without fresh cash circulated on 28 October. A day earlier, Türkiye’s Capital Markets Board (SPK) decided to file criminal complaints against 24 people over trading in Pasifik Eurasia (PASEU). Pasifik’s three shareholders were not on that list. According to a company disclosure, restrictions on their accounts were lifted on 28 October. Contributing shares to a company’s capital does not, by itself, establish wrongdoing.

The claim and the record

The claim originated in an X post by @foveaoberaza. The assertion that the holding started with TRY 1 million could not be corroborated with its incorporation-capital document. Available records establish incorporation in Ankara on 13 June 2023 and subsequent paid-in capital of TRY 6 billion at end-2023, TRY 18 billion at end-2024 and TRY 20 billion after the IPO.

Share transfers and capital growth

KAP disclosures describe the transfers as a move from direct to indirect ownership. Transfer prices total approximately TRY 18.1 billion for the three listed companies. Prices for transfers of the unlisted businesses were not disclosed in the reviewed material.

PSGYO’s transfer price was about 4.4 times the contemporaneous listed B-share price. Different voting rights matter; the material does not explain how the A-share price was determined. PATEK’s TRY 176 price exceeded the 5 April close of TRY 105.80 by about 66%, and the 15 April close of TRY 123.30 by about 43%. The disclosure says the price followed Borsa Istanbul’s wholesale-trading procedure, but does not give the application date or the date on which the price was fixed. PATEK had closed at TRY 177.10 on 14 March.

The IPO: half the gross proceeds went to shareholders

The November 2025 offering sold 4 billion shares at TRY 1.50: 2 billion newly issued shares and 2 billion existing shares. Of TRY 6 billion gross, TRY 3 billion went to the company and TRY 3 billion to the selling shareholders, approximately TRY 1 billion each. Trading began on 21 November. Pricing used net asset value of TRY 30.2 billion and a peer price-to-book multiple of 1.38, followed by a 25% discount. Subsidiary valuations were prepared by Bizim Menkul Değerler.

The announced allocation of company proceeds was 80% for investments, 10% for working capital and 10% for debt. The September report shows cash of approximately TRY 294 million, against an inflation-adjusted TRY 1.56 billion at end-2025. June cash was TRY 589,008. TRY 800 million was contributed to Aden Pelet in January. A detailed proceeds-use reconciliation was not located.

The share closed at TRY 0.77 on 28 October, 48.7% below its offer price; market capitalisation was TRY 15.4 billion. Shareholders had made a one-year no-sale commitment. Reported October purchases were 15 million shares by Fatih Erdoğan and 10 million by Abdulkerim Fırat at around TRY 1.

Book value and quoted market value

The holding uses non-consolidated statements and measures its investments at fair value. Its June note refers to independent valuation reports dated 2 March 2026, using discounted cash flows, quoted market values and net asset values without specifying each company’s method.

Quoted values are The Ledgers’ share-count-times-closing-price calculations, based on the research supplied for this report. They do not automatically equal the fair value of privileged or controlling interests. The June total was already approximately 1.8 times the same-day quoted value. The holding does not disclose whether a control premium was used.

September financial investments totalled TRY 51.81 billion, reflecting inflation adjustments and the Aden contribution. The nine-month cash-flow statement reports zero fair-value gain/loss adjustments, compared with TRY 5.70 billion of gains a year earlier. Over the period from 2 March to 30 September, the supplied price series records declines of 32% for PATEK, 77% for PASEU and 24% for PSGYO. Nine-month revenue fell from TRY 5.87 billion to TRY 250 million; the company reported a TRY 1.54 billion loss against a previous TRY 4.43 billion profit. September equity was TRY 47.88 billion.

IFRS 13’s quoted-price framework is relevant, but share-class differences, the unit of account and any control rights must be assessed before concluding that a valuation violates accounting requirements. The gap alone does not establish a breach.

The fund link: Pardus, then Pusula

Pardus funds AC8, PP4 and PPU acquired 40 million PASEU shares on each of 24, 25 and 28 April 2025. Their combined holding rose from 1.3% to 19.18%. Sellers and transaction prices were not disclosed; applying those closing prices gives approximately TRY 7.2 billion, an estimate rather than confirmed consideration. Mehmet Selim Tunçbilek had led Pardus since August 2024 and left its general-manager role on 12 October 2026, according to reporting.

On 29 April 2026, Pusula funds bought 143.1 million and sold 79.5 million PASEU shares. Their ownership rose from 16.66% to 26.12%, and voting rights from 9.72% to 15.23%. That day Fatih Erdoğan, Mehmet Erdoğan and Abdulkerim Fırat each disclosed sales of approximately 15.67 million shares, while Pasifik Gayrimenkul Yatırım İnşaat sold 20 million: approximately 67 million shares in total. Reported prices were TRY 125.40–134.90.

PASEU’s 27 September statement said the transfers went to Pusula’s PHB fund at market prices in exchange for fund units, not cash. It said the fund was not marketed or open on TEFAS. PSGYO described the arrangement as transferring financial assets between accounts. Fund-data provider fvt lists 15 investors in PHB, established on 30 July 2025.

SPK ordered liquidation of 12 Pusula funds, including PHB, and 42 Pardus funds on 17 September. Pasifik requested return of shares in kind. On 26 October Pusula’s activities were temporarily suspended and Ziraat Bankası was assigned to the remaining funds’ liquidation. PASEU rose from TRY 89 on 8 July to TRY 268 on 28 August, then suffered 22 consecutive limit-down sessions, reaching TRY 26.58 on 29 September and TRY 25.20 on 28 October. The 67 million transferred shares were worth approximately TRY 1.7 billion at the latter price.

What the regulatory record says

SPK bulletin 2026/77 announced complaints against 24 people over PASEU trading under Article 107/1, two-year trading bans and 18 licence cancellations. Pusula chair Muhammed Yarız and former Pardus general manager Tunçbilek appear on the list. The bulletin does not identify the review period or whether the fund purchases described here were the transactions at issue.

Pasifik’s companies and three shareholders are not on that list. PASEU disclosed account restrictions early on 28 October, then at 16:45 disclosed their removal. The company quoted the Istanbul prosecutor as saying Fatih Erdoğan, Mehmet Erdoğan and Abdulkerim Fırat were outside the complaint’s scope and that evidence had been reassessed.

In a separate September fund inquiry, an initial freeze request covered 46 companies, 18 funds and 42 individuals, including the unlisted Pasifik property company. Reporting states that company and fund measures were lifted after a further SPK assessment, while individual restrictions continued. PSGYO rejected the implication of its inclusion. Wider fund-case arrest figures are not findings against Pasifik. The political relationship noted in the Turkish report—Fatih Erdoğan is married to MP Asuman Erdoğan—does not establish influence over either decision; no such link is documented.

A criminal complaint or investigation is not a conviction. The restrictions described against Pasifik interests were lifted.

International comparison: ownership behind funds

The Adani case in India illustrates a disclosure problem, not proof of an equivalent Pasifik scheme. Hindenburg made allegations in 2023, which Adani denied. SEBI introduced additional beneficial-ownership disclosure for certain concentrated foreign funds in August 2023. In September 2025 it dismissed specified related-party and fund-transfer allegations as unsubstantiated; separate fund-ownership inquiries remained. Reuters reported in August 2026 that settlement applications from at least three Mauritius funds were rejected over ownership-disclosure issues.

The distinction matters: Pasifik shareholders themselves disclosed putting their shares into PHB for fund units. The outstanding question is the fund’s full ownership and subsequent transactions. The supplied research reports PASEU’s effective free float at 9.8%.

The unanswered questions

The Ledgers welcomes company, shareholder and institutional responses and will publish substantive replies alongside this report. Prices are dated 28 October 2026; this is a review of records, not a finding of unlawful conduct.

Primary documents: KAP — 30.06.2026, KAP — 30.09.2026, SPK — 2026/77, KAP — 28.10.2026.

Based on reporting from: X — @foveaoberaza, 28.10.2026; Pasifik Holding — 30.06.2026 financial report; Şeker Yatırım — IPO report; KAP 1229840 — PSGYO transfer; KAP 1229844 — PASEU transfer; Rota Borsa — PATEK KAP disclosure; Allbatross — IPO report; İş Yatırım — share-price data; Vakıf Yatırım — IPO report; Capital — IPO results; İş Yatırım — IPO valuation review; Capital — IPO terms; KAP 1688482 — September 2026 financial report; Garanti BBVA — IPO announcement; hisse.net — October share purchases; IFRS Community — fair-value framework; KAP 1429203 — Pardus purchase; KAP 1429725 — Pardus purchase; KAP 1430404 — Pardus purchase; Milli Gazete — Mehmet Selim Tunçbilek; Borsacoo — PASEU transaction summaries; KAP 1599467 — Pusula transactions; Bloomberg HT — portfolio managers; KAP — Fatih Erdoğan sale; KAP — Mehmet Erdoğan sale; KAP — Abdulkerim Fırat sale; KAP — Pasifik Gayrimenkul sale; KAP 1668386 — PASEU fund explanation; Paratic — PSGYO response; fvt — PHB fund data; SPK 2026/60 — liquidation decisions; CNBC-e — temporary suspensions; Para Ajansı — PASEU trading restrictions; SPK 2026/77 — complaints and sanctions; KAP 1688616 — account restrictions; KAP 1689111 — restrictions lifted; soL — September fund inquiry; NTV — restrictions lifted; Milli Gazete — Fatih Erdoğan; Halk TV — company response; Euronews — wider fund investigation; Sözcü — September fund investigation; Business Standard — SEBI decision; Business Standard — fund-disclosure rules; Reuters / Khaleej Times — offshore fund disclosure; fvt — PASEU free float.