App Store and Google Play Commission: Gross or Net? (VAT Base and Revenue Recognition — 2026)

Regulatory note: This article was reviewed on 11 September 2026 against the Turkish VAT Code, the VAT General Implementation Communiqué, TFRS 15, Corporate Tax Code Art. 10/1-ğ, Presidential Decision No. 11257 and the Revenue Administration rulings cited below. Platform agreements and fee structures can change; retain the agreement version used for each period.

“What percentage does Apple or Google retain?” and “Should I present revenue gross or net?” are different questions. Store fees are not fixed; they may vary by country, product, developer programme and payment model. The 100 sale / 30 fee / 70 remittance below is only an illustration.

Three separate assessments are required:

1. Accounting: are you a principal or an agent under TFRS 15?
2. VAT: who is the customer, who receives the invoice and where is the service enjoyed?
3. Accrual: under the agreement, which report and date make the amount sufficiently certain?

The answer in 60 seconds

• Gross or net: This is the result of the TFRS 15 control assessment, not an elective accounting policy. A principal presents gross revenue; an agent presents its net fee or commission.
• Service export: A foreign platform or a foreign-currency payment does not automatically create the Turkish VAT exemption. The foreign-customer and foreign-enjoyment conditions must both be evidenced.
• Revenue period: The bank payment date is not conclusive. Contractual entitlement, an accounting-grade final report and refund/chargeback terms matter together.
• Foreign currency: Art. 280 of the Tax Procedure Code governs valuation; it does not by itself determine the store revenue accrual date.

Start with the contractual model

Under Apple’s current paid-applications agreement, Apple may be appointed as an agent or a commissionaire depending on the territory. Google Play fees and billing structures can also vary by region, programme and product. It is therefore unsafe to assume that Apple and Google always sell in their own name and always retain 30%.

Retain these five items for each period:

1. The accepted platform agreement and applicable schedules,
2. The contractual entity and country shown in the payments profile,
3. The final earnings/financial report intended for accounting,
4. Country-level sales, tax, refund and chargeback data,
5. A reconciliation of the invoice, bank receipt and ledger posting.

Google distinguishes estimated sales data from the earnings report it recommends for accounting and payment reconciliation. Apple’s financial reports similarly show proceeds, taxes, commission and adjustments. Keep downloadable final reports rather than relying on a dashboard screenshot.

Layer 1 — Gross or net revenue under TFRS 15?

TFRS 15 paragraphs B34-B38 require an entity to determine whether it is a principal or an agent when another party is involved in providing goods or services to a customer.

• An entity is a principal if it controls the promised service before that service is transferred to the customer; it presents revenue gross.
• An entity is an agent if its performance obligation is to arrange for another party to provide the service; it presents its net fee or commission.

Primary responsibility, pricing discretion and fulfilment or inventory risk are indicators in the control assessment, not automatic answers. Ownership of the application’s intellectual property does not, by itself, compel gross presentation under every platform agreement.

Example: a sale of 100 units

The user pays 100 units, the platform reports fees and deductions of 30 and remits 70:

Gross and net presentations may reach the same accounting profit in a simplified example, but turnover-linked obligations, the VAT analysis and the evidence trail differ. Deductibility of platform fees also depends on the business connection, supporting documentation and statutory conditions. The two routes therefore do not always produce an identical taxable base.

Layer 2 — Turkish VAT and the service-export exemption

Arts. 11/1-a and 12/2 of VAT Code No. 3065 require both:

1. The service must be supplied for a customer abroad.
2. The service must be enjoyed abroad.

A foreign platform or a payment from abroad cannot replace those conditions. The file should answer:

• Which legal entity is your counterparty under the accepted agreement?
• Do the invoice addressee, contractual counterparty and reporting entity align?
• Is the platform only arranging the supply, or is it the true customer of your service?
• How do users in Turkey and abroad benefit from the service?
• Can country-level revenue be separated using reliable reports?

If the conditions are met, the transaction can be declared without output VAT as a service export. If they are not met, the ordinary VAT rules apply. Do not confuse declaration of the exemption with the separate documentary conditions applicable to a VAT refund claim.

Mixed use: what if there are Turkish users?

Revenue Administration ruling 38808 dated 30 January 2026 concerned a mobile app with users both in Turkey and abroad. On those facts, the administration concluded that the exclusive foreign-enjoyment condition was not met and denied:

• the VAT service-export exemption,
• the Art. 10/1-ğ income deduction, and
• the Art. 32/7 export-income rate reduction.

The ruling is an administrative view on the applicant’s facts, not an automatic conclusion for all platform revenue. It is nevertheless a strong risk indicator for a similar mixed-use model.

The Council of State 3rd Chamber decision E.2022/3559, K.2025/4071 dated 21 October 2025 evaluated accessibility from Turkey differently for advertising/publisher services supplied to a foreign company. Its facts are not the same as an in-app purchase and it does not directly cancel ruling 38808.

Country-level separation is valuable evidence, but segregation alone does not guarantee the exemption. For a material mixed-use model, prepare a contract-customer-enjoyment matrix and consider requesting a fact-specific ruling from the Revenue Administration.

Does reverse-charge VAT apply to the store fee?

The amount retained by the platform may bundle intermediation, distribution, payment and store services received from abroad. The reverse-charge VAT outcome depends on the supplying entity, the service described in the agreement and whether that service is enjoyed in Turkey.

No current Revenue Administration ruling covering every store-fee model was identified. Accordingly, do not assume that:

• no reverse-charge VAT can arise on the foreign-user share,
• VAT on the Turkish share is always neutral, or
• a net accounting entry creates a zero reverse-charge base.

Deductibility of reverse-charge VAT must also be checked against the transaction, documentation, filing period and any input-tax restriction.

Layer 3 — When does revenue accrue?

Payment and accrual are not the same. Determine the period by reviewing:

1. When the developer becomes contractually entitled to the proceeds,
2. Which earnings/financial report is final and accounting-grade,
3. Refund, cancellation, tax, exchange adjustment and chargeback terms,
4. Whether the nature and amount are sufficiently certain at period end.

Neither “every December sale is always December revenue” nor “revenue arises when cash arrives” is a safe universal rule. Tie the documented accounting policy to the agreement and apply it consistently. Art. 280 of the Tax Procedure Code governs foreign-currency valuation; it is not a special rule that makes the payout date the accrual date.

Art. 10/1-ğ and the current 100% rate

Presidential Decision No. 11257 sets the Art. 10/1-ğ deduction rate for eligible service-export income at 100% for accounting periods beginning in 2026. The higher rate does not remove the conditions: eligible activity, a customer abroad, exclusive enjoyment abroad and transfer of the income to Turkey by the corporate-tax return deadline must still be tested.

The Revenue Administration’s 2026 sworn-CPA certification threshold table states, for 2025-period returns, TRY 500,000 for each relevant exemption or deduction and TRY 1,000,000 in aggregate where the individual threshold is not exceeded. These are period-specific limits; recheck the table and any full-certification exception for the year claimed.

Practical control list

1. Freeze the platform agreement, schedule, territory and acceptance date.
2. Download the accounting-grade earnings/financial report, not estimated analytics.
3. Reconcile gross sales, fees, tax, refunds and chargebacks.
4. Document the TFRS 15 control assessment and principal-agent conclusion.
5. Align the counterparty, invoice addressee, true customer and user geography.
6. Analyse service-export VAT and potential reverse-charge VAT separately.
7. Tie the accrual and FX policy to the contractual entitlement terms.
8. Test the Art. 10/1-ğ 100% deduction, transfer-to-Turkey and sworn-CPA certification requirements.

For a documented contract-report-invoice-return process, see our SaaS and mobile-app accounting service. If you are still choosing the entity and regime, continue with setting up a game studio in Turkey.

Official sources

• Public Oversight Authority — TFRS 15 Revenue from Contracts with Customers
• Revenue Administration — VAT General Implementation Communiqué
• Revenue Administration — Corporate Tax General Communiqué
• Revenue Administration ruling — software and design services supplied abroad (31011)
• Revenue Administration ruling — mobile app with domestic and foreign users (38808)
• Presidential Decision No. 11257 — service-export deduction rate
• Apple Developer — Apple Developer Program License Agreement
• Google Play Console Help — service fees
• Google Play Console Help — financial reports

This article is general information. Review the platform agreement, invoice parties, user geography and revenue model for the specific transaction.