Insights · Istanbul
Pieces on foreign investor onboarding, IFM/NHM regime, Pillar Two, Technopark and SME structuring — published from Istanbul.
Which game revenue streams does the technopark earnings exemption (Law 4691) actually cover? How in-app purchases, App Store/Google Play/Steam cuts, in-game ads and publisher royalties are taxed in 2026 — and which income falls outside the exemption.
Read the pieceTwo Turkish incentive regimes, two different mechanics: Law No. 4691 (technopark) exempts the earnings, while Law No. 5746 (R&D center) deducts the expense. This 2026 comparison covers the corporate tax exemption to 31 December 2028, the 100% R&D deduction, payroll income-tax withholding incentives, employer social-security support, the venture-capital fund obligations (3% vs 2%), and the statutory ban on claiming both regimes for the same activity (Law 5746 Art. 4/5).
Read the pieceTwo routes for companies exporting software/SaaS from Turkey: the 100% earnings exemption inside a technopark (Law 4691), or deducting 80% of the earnings from the tax base via Corporate Tax Law Art. 10/1-ğ without entering any zone. 2026 conditions, effective tax burden and decision criteria.
Read the pieceTechnopark (Law 4691), R&D/Design Centre (Law 5746) and Qualified Service Centre (Law 7582 / CITL art.10/1-j) side by side: zone requirement, headcount threshold, exemption vs. deduction, duration, the double-benefit ban and Pillar Two 15%. Decision matrix + decision tree.
Read the pieceLaw No. 4691 Provisional Article 2 grants 100% corporate income tax exemption on software, design and R&D earnings in Turkish Technology Development Zones until 31 December 2028. For foreign investors the headline is attractive, but the operational picture is complex: branch requirement (liaison office structurally excluded under Law 4875), 3% venture capital fund obligation triggered at TL 5,000,000 exempt earnings for FY 2026 (Presidential Decree 10803, Official Gazette 31.12.2025), CPA (YMM) full-attestation report mandatory above TL 500,000 single item or TL 1,000,000 aggregate (Tebliğ 49, OG 30.12.2025), and the 40× minimum wage cap on payroll incentives at TL 1,321,200/month/employee for 2026 (Law 7555, OG 24.07.2025). Compared with Ireland Knowledge Development Box (10% effective, Section 40 Finance Act 2022, commencement order signed 5 Sept 2023, operative 1 Oct 2023) and UK Merged RDEC (20% headline, 15% net), Turkey wins for groups under €750M consolidated revenue; above that, OECD Pillar Two QDMTT (Law 7524) tops the rate up to 15% because the Turkish exemption is not a qualifying refundable tax credit.
Read the pieceRelocating an 80-person Latvian game studio to Turkey: the A.Ş. decision, Technopark regime, 100% service-export deduction, transfer pricing.
Read the pieceA company in Türkiye isn't set up 'in a day': from first contact to first invoice there are 14 clear steps. The JSC capital-blockage account opens remotely; the only physical requirement is the active commercial bank account.
Read the pieceIn 2026 the young-entrepreneur Bağ-Kur premium support ended and tax brackets rose. Should a new entrepreneur set up as a sole proprietor or a limited company? The break-even, in numbers.
Read the pieceTurkey's GVK Article 20/D non-dom regime, enacted by Law No. 7582, grants a 20-year exemption on foreign-source income; Communiqué No. 333 ties the exemption to a time-limited 'Exemption Certificate' obtained from the tax office. The 10% domestic minimum corporate tax still erodes the 9% reduced rate for manufacturer-exporters.
Read the pieceLaw 7582 rewrote CITC Art. 10/1-(i): 95% of the income from selling foreign-bought goods abroad without bringing them into Turkey — 100% for IFC participants — is deducted from the corporate-tax base. Communiqué No. 26 examples, the late-transfer trap, the game/e-pin code scope, and the Pillar Two interaction.
Read the pieceA 100% Turkish corporate-tax exemption for IFC/qualified service centers pushes a constituent entity's GloBE rate below 15% — and Turkey's own QDMTT claws the difference back. The only shield is substance.
Read the pieceTürkiye's Law No. 7582, published in the Official Gazette on 4 June 2026 (No. 33270), rewrites the IFC ecosystem on two layers: extending the 100% corporate tax exemption to 2047, and introducing the Qualified Service Centre (QSC) status. Effective 0% corporate tax on foreign-source income, personnel salary exemption up to six times the minimum wage, full transit-trade relief in IFC and Industry Zones. But Pillar Two QDMTT, substance and transfer pricing decide who actually keeps the benefit.
Read the pieceA Turkish liaison office offers zero tax and low cost; but Law No. 4875 will not let you convert it directly into a JSC or QSC. Most of the 200+ active offices are unaware of this structural limit.
Read the pieceA reading of Turkey's Century Investment Package for foreign investors considering Turkey. Not praise — a map.
Read the pieceLaw No. 7582 doubles the income-tax exemption cap on shares granted to tech-startup employees from one to two times annual gross salary; the real risk is that non-qualifying joint-stock companies tax the share as full salary under Income Tax Code Art. 61.
Read the pieceWhat period does the Law No. 7582 wealth-amnesty protection actually cover? A Q&A: the test is a single question — at the moment of declaration, has that period's filing deadline already passed?
Read the pieceDividends arrive with a 36.25% burden, but a director's fee (huzur hakkı) paid to a managing partner is both deductible for the company and almost untaxed on the first TRY 33,030/month. The optimum amount and the arm's-length limit for 2026.
Read the pieceAs of July 2026 Turkey has no crypto-specific tax law in force — the bill's crypto articles were withdrawn in the General Assembly on 27.03.2026. But that is not 'tax-free': general Income Tax provisions, GİB rulings and CARF visibility already bind the taxpayer today.
Read the pieceFor people who paid premiums under several statuses (SSK + Bağ-Kur + Emekli Sandığı), Turkey's SSI grants the pension from whichever status carried more service in the last 7 years before the claim (Law No. 2829, Art. 8) — often the Bağ-Kur track that demands 9,000 days. Yet the Court of Cassation's Assembly of Civil Chambers reaffirmed that an insured who already qualifies under a single status cannot be forced into service merger; their will prevails. This is not a new invention but confirmation of settled precedent at Assembly level.
Read the pieceUnder ITL Art. 23/1-(20), the portion of a QSC qualified employee's wage up to 3 times the gross minimum wage (5 times in the IFC and eligible industrial zones) is exempt from income and stamp tax. Communiqué No. 334 examples, a payroll simulation, and what the Communiqué does not say.
Read the pieceSwitching your Turkish accountant is your right — but your books can't be held hostage, digital authorities must transfer, and prior-period liability survives.
Read the pieceAn e-notification is deemed served at the end of the 5th day after it reaches your address; the Council of State says it is valid even if no SMS/e-mail alert arrives. The Constitutional Court's 2026 annulment shakes this ground, but it takes effect on 3 January 2027. The taxpayer's only defence is a disciplined checking routine.
Read the pieceFrom a file we recently took over: during a staff leave period, a single notice slipped through a control gap and — under the 5-day rule — closed the right to appeal. The fix: 24/7 mobile monitoring plus a dual-verification protocol.
Read the pieceCompany incorporation in Türkiye takes a week — opening a bank account can take months. Six structural barriers and three golden rules.
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July 16, 2026 Law 7582 rewrote CITC Art. 10/1-(i): 95% of the income from selling foreign-bought goods abroad without bringing them into Turkey — 100% for IFC participants — is deducted from the corporate-tax base. Communiqué No. 26 examples, the late-transfer trap, the game/e-pin code scope, and the Pillar Two interaction.
July 10, 2026 As of July 2026 Turkey has no crypto-specific tax law in force — the bill's crypto articles were withdrawn in the General Assembly on 27.03.2026. But that is not 'tax-free': general Income Tax provisions, GİB rulings and CARF visibility already bind the taxpayer today.
July 10, 2026 For people who paid premiums under several statuses (SSK + Bağ-Kur + Emekli Sandığı), Turkey's SSI grants the pension from whichever status carried more service in the last 7 years before the claim (Law No. 2829, Art. 8) — often the Bağ-Kur track that demands 9,000 days. Yet the Court of Cassation's Assembly of Civil Chambers reaffirmed that an insured who already qualifies under a single status cannot be forced into service merger; their will prevails. This is not a new invention but confirmation of settled precedent at Assembly level.
July 9, 2026 Which game revenue streams does the technopark earnings exemption (Law 4691) actually cover? How in-app purchases, App Store/Google Play/Steam cuts, in-game ads and publisher royalties are taxed in 2026 — and which income falls outside the exemption.
July 9, 2026 Two Turkish incentive regimes, two different mechanics: Law No. 4691 (technopark) exempts the earnings, while Law No. 5746 (R&D center) deducts the expense. This 2026 comparison covers the corporate tax exemption to 31 December 2028, the 100% R&D deduction, payroll income-tax withholding incentives, employer social-security support, the venture-capital fund obligations (3% vs 2%), and the statutory ban on claiming both regimes for the same activity (Law 5746 Art. 4/5).
Earlier insights are grouped by cluster above.
