Insights · Istanbul
Tax strategy in plain words.
Pieces on foreign investor onboarding, IFM/NHM regime, Pillar Two, Technopark and SME structuring — published from Istanbul.
Latest
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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 service export deduction rising to 100% is not a question of the rate but of exclusivity. On mixed sales, ruling No. 143061 refuses categorically; and in 2026 the sole proprietorship versus limited company equation turned IN FAVOUR of the sole proprietorship because of CTC Art. 32/C.
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
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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
All posts
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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 service export deduction rising to 100% is not a question of the rate but of exclusivity. On mixed sales, ruling No. 143061 refuses categorically; and in 2026 the sole proprietorship versus limited company equation turned IN FAVOUR of the sole proprietorship because of CTC Art. 32/C.
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 foreign currency 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 -
Apple and Google Play's 30%: Is the Store Commission Taxed Gross or Net? (VAT Base and Revenue Recognition — 2026)
The store keeps 30% and remits the rest; so is your revenue 100 or 70, to whom and for what amount do you issue the VAT invoice, and in which month does the income arise? 'Gross or net' is not one question — it is three layers that get mixed up: revenue recognition, the VAT base and the moment of accrual. The Revenue Administration's ruling of 30.01.2026 and the Council of State's decision of 21.10.2025 point in opposite directions on mixed use.
11 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 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).
9 min read -
Provisional Tax for the Self-Employed in Turkey: Setting the 15% Up Correctly in 2026 and Crediting the Withholding You Paid
A self-employed professional pays provisional tax of 15% of earnings in quarterly periods; at year end both the provisional tax and the 20% withholding are credited against the annual income tax. The mechanism with 2026 figures, and the mistakes made most often.
8 min read -
The Social Content Creator Exemption (GVK rep. Art. 20/B): Turkey's TRY 5,300,000 Threshold and the 15% Bank Withholding in 2026
For YouTubers, Instagram and TikTok creators and mobile app developers, repeated Article 20/B of the Income Tax Code turns tax into a single automatic deduction: revenue is collected through a dedicated Turkish bank account and the bank withholds 15% as a final tax. Cross the TRY 5,300,000 threshold in 2026 and the exemption disappears — not partly, entirely.
8 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 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.
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 Turkey: A Guide to Communiqué No. 334 — Tax-Free Salary up to TRY 99,090/Month (TRY 165,150 in the IFC) (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 2026: The Legal Way a Partner Draws Up to TRY 33,030 a Month From the Company Almost Tax-Free — and Its Limit
Dividends 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.
9 min read -
Turnkey Company Formation in Turkey (2026): A Foreign Investor's 14-Step Roadmap from First Contact to First Invoice
A 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.
13 min read -
Changing Your Accountant in Turkey (2026): A Complete Handover, E‑Ledger and Digital Authority Guide
Switching your Turkish accountant is your right — but your books can't be held hostage, digital authorities must transfer, and prior-period liability survives.
11 min read -
Turkey's 100% QSC/IFC Exemption Meets Pillar Two: The QDMTT Clawback and the Substance Shield (2026)
A 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.
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? The Two Numbers That Changed the 2026 Equation for New Entrepreneurs in Türkiye
In 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.
9 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 shakes this ground, but it takes effect on 3 January 2027. The taxpayer's only defence 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: 24/7 mobile monitoring plus a dual-verification protocol.
4 min read -
Turkey Technopark 2026: 100% Corporate Tax Exemption and Hidden Compliance Costs
Law 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.
11 min read -
Türkiye Liaison Office 2026: Setup, Zero-Tax Advantage and the Conversion Trap
A 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.
8 min read -
Istanbul Financial Centre 2026 Reforms: Five Concrete Advantages, Three Risks and the 2047 Horizon
Türkiye'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.
10 min read -
Turkey's 2026 Non-Dom Regime and the 10% Minimum Corporate Tax Paradox
Turkey'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.
10 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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