Apple and Google Play's 30%: Is the Store Commission Taxed Gross or Net? (VAT Base and Revenue Recognition — 2026)

Regulatory Note: This article was prepared as at 2026-07-23 on the basis of Arts. 11/1-a and 12/2 of the VAT Code No. 3065, the VAT General Implementation Communiqué (II/A-2), Art. 10/1-ğ of the Corporate Tax Code No. 5520, Art. 280 of the Tax Procedure Code No. 213, the Revenue Administration’s ruling No. E-62030549-125 dated 30.01.2026, and the Council of State 3rd Chamber’s decision E.2022/3559 K.2025/4071 dated 21.10.2025. Legislation changes; confirm the current text and your own position before transacting.

The store collects the money at month end, keeps 30%, and sends the rest to your account 30-45 days later. Then bookkeeping time arrives and a single question locks up the whole table: is my revenue 100, or 70?

The question is not as innocent as it looks. Because it is not a single question. Beneath it lie three separate layers that get mixed up, and the three do not give the same answer.

The answer in 60 seconds

To resolve “gross or net”, first split it into three:

1. Revenue recognition — do you book 100 or 70? This is an accounting-standard question (the principal-agent distinction).
2. The VAT base — to whom, for what amount and under which exemption do you issue the invoice? This is a question under Art. 11/1-a of Code No. 3065.
3. The moment of accrual — in which month does the income arise; the day the money lands, or the month of the sale? This is a question under the Tax Procedure Code No. 213.

The short answer: for most studios, revenue in the eyes of the accounting standard is gross 100 and the commission of 30 is a separate expense; on the VAT side the transaction falls within the service-export exemption; and the income arises not on the day the money arrives but in the month the sale takes place. But if there is mixed use, the equation changes entirely. Let us take them in order.

Is the store your customer or your commission agent?

Clarify the counterparty first, because the entire mechanics of the service-export exemption follow from it.

Apple and Google sell your app in their own stores in their own name, collect payment, keep a 30% commission and pay you the rest. This is a classic commissionaire model: the legal face of the sale is the store, the economic owner is you.

Industry practice and the developer agreements point to the foreign store entity as the addressee of the invoice — Apple Distribution International Ltd. (Cork) or Google Ireland Ltd. (Dublin). That maps exactly onto the “customer abroad” condition of the service-export exemption.

Here I need to be honest. The Revenue Administration’s ruling of 30.01.2026 approaches the “customer” through the end-user; it does not name Apple or Google as the invoice addressee. So the sentence “you invoice the Irish company directly” is a consequence of the contractual structure and market practice, not the wording of the primary ruling. In practice the two coincide; but standing on that distinction knowingly protects you at an audit desk.

Gökay GÜL’s note: Match your payout report to your e-Archive invoice every month and file it. When an audit arrives, the first thing asked is which store report the amount you declared rests on. If the report-invoice-declaration trio does not reconcile, you will spend three weeks writing a defence even where you are right.

The three layers that get mixed up

Layer 1 — Revenue: 100 or 70?

This is a principal-agent question. You hold the intellectual property, you set the price, you are responsible for the product. In the eyes of the accounting standard that makes you the principal: revenue is booked gross at 100, and the 30% commission is written as 30 in a separate selling-and-marketing expense line.

In practice many studios write the net 70 as revenue on a single line. For the corporate tax base the two routes usually reach the same profit: on the gross presentation, income of 100 less expense of 30; on the net presentation, income of 70. Both leave a base of 70.

But the two presentations diverge in the VAT base and in obligations tied to turnover thresholds. A studio booking net understates its turnover; one booking gross carries the correct turnover but must document the commission. The prudent route is gross recognition plus a separate commission expense.

Layer 2 — The VAT base and the exemption

The transaction is a service export within the scope of Art. 11/1-a of Code No. 3065: a service performed for a customer abroad and enjoyed abroad is exempt from VAT. Art. 12/2 imposes two conditions — the service must be performed for a customer abroad, and it must be enjoyed abroad. The VAT General Implementation Communiqué (II/A-2) repeats this verbatim.

So you issue your e-Archive invoice without calculating VAT, under a full exemption. In practice this transaction is declared on the No. 1 VAT return in the full-exemption line (code 302); but that is only a return-filing practice, not a provision of a ruling, so I do not present it as a citation.

Do not confuse a critical distinction. For declaring the exemption it is not necessary for the consideration to reach Turkey. But if you want a refund of the VAT you have incurred, the consideration must have arrived in Turkey in foreign currency and been documented by a bank. Declaration is one thing, refund another.

Layer 3 — Accrual: in which month does the income arise?

Income arises not when the money enters your account but when it becomes certain in nature and amount. The store’s month-end payout report is the document of that certainty. That it sends the money 30-45 days later does not change the moment of accrual.

This creates a period-shift risk. The report for an app sold in December is issued in December but the money arrives in January. If you book the income to January you under-declare one period and over-declare the other — the classic doorway to a penalised assessment. A December sale accrues to December.

The exchange rate is also tied to that date. Art. 280 of the Tax Procedure Code No. 213 sets the rule for valuing foreign currency; in practice the Central Bank buying rate at the payout date is taken, not the rate on the transfer day. The difference is treated separately as an exchange gain or loss.

Let me be clear: there is no specific provision tying the exact month in which store income accrues to a dated and numbered ruling. This timing follows from the general accrual and periodicity principles; Art. 280 of the Tax Procedure Code supplies only the valuation limb. So it is not a rule, but the principle applied to the store.

A numerical comparison: a sale of 100 units

The end-user paid 100 units, the store kept 30, and remitted 70. The two presentations side by side:

The two presentations meet at the profit base and part company on turnover and on documentation. The Revenue Administration’s approach is close to a gross-revenue basis; gross recognition therefore protects you from surprises.

The riskiest area: mixed use

Now we reach the real fault line. Do only foreign users download your app, or do Turkish users play it too?

The Revenue Administration’s ruling of 30.01.2026 speaks plainly: if the app is also open to users in Turkey, the condition of “exclusive enjoyment abroad” falls away. Then there is no service-export exemption (Art. 11/1-a); there is no 80% income deduction under Art. 10/1-ğ of Code No. 5520; and there is no 5-point export reduction under Art. 32/7 — and on the administration’s view this applies to the whole of the income where mixed income cannot be separated.

The Council of State’s 3rd Chamber looks the other way. In its decision E.2022/3559 K.2025/4071 dated 21.10.2025, in a case where the direct beneficiary of the service was a foreign company, it holds: the fact that users in Turkey can also reach the service the foreign company purchased does not by itself remove the condition that the service is enjoyed abroad, and the transaction therefore remains within the service-export exemption. The exemption stands.

Two primary sources, diametrically opposed on mixed use. But the fact patterns are not identical: the Council of State decision concerns advertising/publisher income (the counterparty being Google Ireland), not in-app purchases. Moreover it is a chamber reversal decision, not settled case law — the file can return to the litigation chamber. So I do not press it as “the Council of State says the same for in-app sales”; I present it as the same accessibility principle on different facts.

The prudent route: treat the portion attributable to domestic users as subject to VAT at the general rate (20%) and declare the foreign portion as exempt, while preserving the litigation route. This is the area of highest tax risk; make the decision on a documented rationale.

Is there reverse-charge VAT on the store commission?

The 30% the store keeps is an intermediation service you receive from abroad. Art. 6/b of the VAT Code sets the place-of-enjoyment principle. From there the question of reverse-charge VAT (the No. 2 return) arises.

On the commission attributable to foreign users the benefit is abroad; no reverse-charge VAT arises. On the commission attributable to domestic users the benefit is in Turkey; in theory a 20% reverse-charge declaration comes into play, and the final burden is usually neutralised through deduction in the same period. On the net presentation the base is in practice close to zero; on the gross/principal presentation it is contested. I could not find a dated and numbered ruling or case law specific to the store commission; I keep this item separate as “contested” and do not write it as settled law.

Do not skip the CPA certification threshold

There is also a quiet obligation. General Communiqué No. 49 on CPAs and Sworn CPAs (Official Gazette 30.12.2025, issue 33123) brought the Art. 10/1-ğ income deduction within the scope of certification. If your deduction exceeds TRY 500,000, a sworn-CPA certification report is compulsory from the 2025 accounting period. A report is also required if the total of exemptions that individually stay below the threshold exceeds TRY 1,000,000. If you have a full-certification engagement, no separate report is required.

So if you are using the 80% deduction, plan the certification report that will document it as carefully as the deduction itself.

What you should do

The skeleton of declaring store income correctly is five steps: obtain the payout report, see the net and gross amounts separately, issue the e-Archive invoice under the service-export exemption, accrue the income to the payout month, and bring in and document the foreign currency. Track the domestic-user ratio separately. All the risk is there.

Incorporation and regime choice also change this picture — setting up a game studio in Turkey and how revenue types separate under the technopark exemption sit immediately adjacent to this topic.

If you would like to settle the tax structure of the store commission against your own numbers, we can build your payout-invoice-declaration chain together at Sistem Global Danışmanlık. For details and contact, write via gokaygul.com.