Insights · Istanbul
Tax strategy in plain words.
Pieces on foreign investor onboarding, IFM/NHM regime, Pillar Two, Technopark and SME structuring — published from Istanbul.
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POS Total Does Not Match the VAT Return: 4 Steps to Reconcile Line 45 (2026)
What should you do if the POS Transaction Information screen launched by the Turkish Revenue Administration on 11.08.2026 does not match line 45 of VAT Return No. 1? This four-step guide helps you reconcile the difference in your books and prepare for the 30-day explanation period under TPC (VUK) Art. 370 if the tax administration invites you to explain.
15 min read -
VUK Communiqué No. 595: Digital Platforms Do Not Report the Same Data
Communiqué No. 595 gives hosting and social-network providers a separate data set. A platform's role determines which identity, listing, payment and bank data it reports.
15 min read -
Earning $5,000 on Upwork: Who Do You Invoice, and How Do Escrow and the 100% Earnings Deduction Fit Together? (2026)
How is the document counterparty for Upwork, Fiverr and Toptal income found in the contract; and how do escrow release, collection and the transfer to Turkey differ?
15 min read
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The 2026 100% Earnings Deduction for Game and App Developers: Sole Proprietorship or Limited Company on the Steam, App Store and Google Play Front?
The 100% service-export deduction is a question of conditions and evidence, not only the rate. Mixed sales, CTC Art. 32/C and repeated Art. 20/B must be modelled separately.
14 min read -
The 100% Service Export Deduction in Mixed-Customer SaaS: Two Tax Regimes From One Set of Earnings, and the TRY 560,000 Certified Public Accountant Threshold (2026)
Turkish and foreign customers pay for the same SaaS subscription. Splitting the earnings, the exclusive-benefit test and the TRY 560,000 sworn-in CPA certification threshold have to be managed together.
12 min read -
You Got the 100% Deduction and Still Owe Tax: Turkey's Minimum Corporate Tax Wall (2026)
The service-export deduction is 100% from 1/1/2026. The whole profit leaves the tax base, yet the return still shows tax due: Art. 10/1-ğ cannot be subtracted from the domestic minimum corporate tax base.
11 min read -
What Does Turkey's Technology Venture Badge Actually Get You? The Answer Changed in 2026
In 2025 the badge was a prestige certificate. On 4 June 2026 it was written into statute, on 9 July it was tied to a KOSGEB loan — and the risk of losing it arises in your own funding round.
11 min read -
Your Trademark Can Be Attached but Is Not on the Collateral List: The Asymmetry Inside Law 6183
The tax office can attach your trademark; offer the same trademark as collateral and you run into the wording of the statute. The gap sits in two articles of Law 6183.
13 min read -
Shareholder Covers the Company's Loss: Is There Tax? With a Resolution No, Without One Yes (TCC Art. 376)
Same money, two tax fates: with a general assembly resolution the fund is untaxed; without one, the administration's current view brings 25% corporate tax, and where the taxpayer is in scope, a 10% minimum tax.
11 min read
All posts
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POS Total Does Not Match the VAT Return: 4 Steps to Reconcile Line 45 (2026)
What should you do if the POS Transaction Information screen launched by the Turkish Revenue Administration on 11.08.2026 does not match line 45 of VAT Return No. 1? This four-step guide helps you reconcile the difference in your books and prepare for the 30-day explanation period under TPC (VUK) Art. 370 if the tax administration invites you to explain.
15 min read -
VUK Communiqué No. 595: Digital Platforms Do Not Report the Same Data
Communiqué No. 595 gives hosting and social-network providers a separate data set. A platform's role determines which identity, listing, payment and bank data it reports.
15 min read -
Earning $5,000 on Upwork: Who Do You Invoice, and How Do Escrow and the 100% Earnings Deduction Fit Together? (2026)
How is the document counterparty for Upwork, Fiverr and Toptal income found in the contract; and how do escrow release, collection and the transfer to Turkey differ?
15 min read -
The 2026 100% Earnings Deduction for Game and App Developers: Sole Proprietorship or Limited Company on the Steam, App Store and Google Play Front?
The 100% service-export deduction is a question of conditions and evidence, not only the rate. Mixed sales, CTC Art. 32/C and repeated Art. 20/B must be modelled separately.
14 min read -
The 100% Service Export Deduction in Mixed-Customer SaaS: Two Tax Regimes From One Set of Earnings, and the TRY 560,000 Certified Public Accountant Threshold (2026)
Turkish and foreign customers pay for the same SaaS subscription. Splitting the earnings, the exclusive-benefit test and the TRY 560,000 sworn-in CPA certification threshold have to be managed together.
12 min read -
You Got the 100% Deduction and Still Owe Tax: Turkey's Minimum Corporate Tax Wall (2026)
The service-export deduction is 100% from 1/1/2026. The whole profit leaves the tax base, yet the return still shows tax due: Art. 10/1-ğ cannot be subtracted from the domestic minimum corporate tax base.
11 min read -
What Does Turkey's Technology Venture Badge Actually Get You? The Answer Changed in 2026
In 2025 the badge was a prestige certificate. On 4 June 2026 it was written into statute, on 9 July it was tied to a KOSGEB loan — and the risk of losing it arises in your own funding round.
11 min read -
Your Trademark Can Be Attached but Is Not on the Collateral List: The Asymmetry Inside Law 6183
The tax office can attach your trademark; offer the same trademark as collateral and you run into the wording of the statute. The gap sits in two articles of Law 6183.
13 min read -
Shareholder Covers the Company's Loss: Is There Tax? With a Resolution No, Without One Yes (TCC Art. 376)
Same money, two tax fates: with a general assembly resolution the fund is untaxed; without one, the administration's current view brings 25% corporate tax, and where the taxpayer is in scope, a 10% minimum tax.
11 min read -
Limited Company or Joint Stock Company? In 2026 the Decision Is Made by the Exit, Not the Formation
The choice between a limited company and a joint stock company is always explained through capital and prestige. The real difference, though, appears not when you form the company but when you sell the shares — and the tax gap can run to hundreds of thousands of lira.
11 min read -
RSUs From a Foreign Parent: The Tax That Lands Before the Cash, and the Social-Security Cost Nobody Mentions
An RSU can be taxed before you ever sell the share — the trigger is when legal and economic control passes to you. The 2026 exemption is closed to most multinational subsidiaries, and income tax is not the whole bill.
12 min read -
Invoicing Abroad Is Not Enough: In SaaS, 'Where the Benefit Is Used' Decides the VAT Exemption (2026)
Selling SaaS or software to a foreign customer and issuing a VAT-free invoice does not, by itself, mean the service-export exemption applies. Turkey's VAT service-export exemption requires two conditions together: the service must be performed FOR a customer abroad AND the benefit must be USED abroad. The second condition is the real test: if the benefit is tied to an activity in Turkey, 20% VAT may arise. The administration reads mixed use strictly, while the judiciary examines the actual service recipient and place of benefit on the specific facts. Two further traps: bringing the service fee to Turkey is a condition for the REFUND, not for the exemption; and this VAT exemption is separate from the CIT Art. 10/1-(ğ) earnings deduction.
12 min read -
App Store and Google Play Commission: Gross or Net? (VAT Base and Revenue Recognition — 2026)
Whether App Store or Google Play revenue is presented gross or net depends on the TFRS 15 principal-agent assessment, not a fixed commission rate. The Turkish VAT and service-export outcome requires a separate review of the contractual counterparty, invoice addressee, user geography and place of enjoyment.
12 min read -
I Bought a Car Through My Company, So I'll Deduct It From Tax: Why Half of That Sentence Is Wrong in 2026
In 2026, four ceilings and a single rate stop most of the 'put the car in the company and the tax drops' expectation from actually reducing the tax base: monthly rent 46.000 TL, purchase SCT+VAT 1.200.000 TL, depreciation capped at 1.380.000 / 2.600.000 TL; 70% of running costs are deductible, 30% is added back as a non-deductible expense. The real lever, though, is a question nobody asks: is the vehicle a passenger car (87.03) or a commercial one (87.04)?
12 min read -
Sell Without Bringing Goods Into Turkey: 95% of the Income Is Tax-Deducted (100% in the IFC)
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.
14 min read -
Crypto Tax in Turkey 2026: The Gap Between What's 'Arrived' and What's Actually in Force
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.
13 min read -
Reduced Corporate Tax in Turkey 2026-2027: 12.5% on Manufacturing, 20% on Exports — Who, When and How?
Law No. 7582 cut the corporate tax rate on manufacturing earnings covered by an industrial registry certificate, and on agricultural production, to 12.5%. But when that rate starts to apply, whether it combines with the export deduction, and how it interacts with the 10% minimum corporate tax floor are set up wrongly by most taxpayers. For software and game companies the industrial registry certificate is a separate critical axis.
14 min read -
The Pension "Last 7 Years" Trap: Turkey's SSI Cannot Force You Into Bağ-Kur — What the Court of Cassation Ruled
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.
13 min read -
Game Companies & the Technopark Exemption: In-App, Store Cut, Ad Revenue (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.
9 min read -
R&D Center or Technopark? 2026 Incentive Comparison (Turkey)
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 incentives, the 3% venture-capital obligation under Presidential Decree 10803, and the statutory ban on claiming both regimes for the same activity.
9 min read -
Turkey Self-Employment Provisional Tax 2026: Four Periods and Withholding Credits
A source-backed 2026 guide to Turkey's self-employment provisional tax: four filings, same-day filing and payment, e-SMM withholding and no double credit.
11 min read -
Turkey's Content Creator Tax Exemption in 2026: TRY 5.3M Limit and Application
A practical guide to repeated Article 20/B: qualifying creators and online services, the certificate and Turkish bank-account process, 15% withholding and what changes above TRY 5.3 million.
12 min read -
Software Firms: Technopark or Service-Export Deduction? (2026)
Two routes for companies exporting software/SaaS from Turkey: the 100% earnings exemption inside a technopark (Law 4691), or deducting 100% of qualifying earnings under Corporate Tax Law Art. 10/1-ğ without entering any zone. 2026 conditions, minimum corporate tax effect and decision criteria.
8 min read -
Technopark, R&D Centre, or QSC? A 2026 Decision Guide for Software and Game Studios in Turkey
Technopark (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.
14 min read -
Qualified Service Center Payroll Exemption in Türkiye: Communiqué No. 334 Guide (2026)
Under 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.
12 min read -
Turkey's 2026 Wealth Amnesty Q&A: The Real Temporal Limit of the Protection
What 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?
12 min read -
Director's Fee in Türkiye (2026): Tax, Social Security, Dividends and the Arm's-Length Test
An official-source guide to the Turkish tax, social-security, dividend and arm's-length rules for a director's fee paid to a shareholder in 2026.
11 min read -
Foreign-Owned Company Formation in Türkiye (2026): 14 Steps from Registration to First Invoice
A practical guide to MERSIS, powers of attorney, shareholder-level JSC capital deposits, bank KYC, tax registration and the first-invoice route for a foreign-owned Turkish company.
12 min read -
Changing Your Accountant in Turkey (2026): Handover, e-Ledger and Digital Authority Guide
A change of accountant requires valid termination, a documented return of records and secure digital authorization—not a transfer of the taxpayer's passwords.
12 min read -
Turkey's QSC/IFC Deduction Meets Pillar Two: QDMTT and SBIE Analysis (2026)
A 95%/100% QSC deduction may reduce the Turkish jurisdictional GloBE rate. The QDMTT outcome requires blending, covered taxes, elections, safe harbours and SBIE.
11 min read -
Turkey's 2026 ESOP Turning Point: The Employee Share Exemption Cap Doubles
Law 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.
10 min read -
Sole Proprietorship or Limited Company in Türkiye? 2026 Decision Guide
An official-source comparison of a sole proprietorship and limited company in Türkiye: 2026 tax, young-entrepreneur relief, social security, dividends and liability.
12 min read -
In e-Notification the Clock Runs Against You: the Council of State Already Started Counting Day 5
An 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 takes effect on 3 January 2027. The safest operational protection is a disciplined checking routine.
8 min read -
How One Missed e-Notification During a Leave Period Wiped Out a 30-Day Right to Appeal
From 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: routine checks plus a dual-verification protocol.
4 min read -
Turkey Technopark 2026: Tax and Compliance Guide for Foreign Investors
A foreign investor should test the Turkish Technopark regime across entity choice, qualifying profit, the 3% investment obligation, YMM attestation, payroll, VAT and Pillar Two.
12 min read -
Türkiye Liaison Office 2026: Setup, Tax Treatment and Company Transition
A Turkish liaison office may conduct non-commercial market research and representation work. It cannot generate revenue, and there is no direct conversion route into a company or QSC.
10 min read -
Istanbul Financial Centre 2026 Reforms: Five Concrete Advantages, Three Risks and the 2047 Horizon
Law No. 7582 extends IFC incentives to 2047 and introduces the Qualified Service Center regime: a conditional 95%/100% profit deduction, three/five-times payroll caps and Pillar Two exposure.
9 min read -
Türkiye's 20-Year Foreign-Income Exemption: Communiqué No. 333 and the Exemption Certificate (2026)
ITL repeated Article 20/D exempts qualifying foreign-source income of eligible new Turkish residents for 20 years. The three-calendar-year test, Annex-1 Exemption Certificate, source rules and foreign-tax risk under Communiqué No. 333.
12 min read -
A Foreign Game Studio's Journey into Turkey: From the First Email to the First Dividend
Relocating an 80-person Latvian game studio to Turkey: the A.Ş. decision, Technopark regime, 100% service-export deduction, transfer pricing.
8 min read -
Istanbul's 20 Years: Is a Tax Holiday Enough?
A reading of Turkey's Century Investment Package for foreign investors considering Turkey. Not praise — a map.
9 min read -
From Bureaucracy to Geopolitics: The Invisible Side of Banking for Foreign Investors in Türkiye
Company incorporation in Türkiye takes a week — opening a bank account can take months. Six structural barriers and three golden rules.
4 min read
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