Game Companies & the Technopark Exemption: In-App, Store Cut, Ad Revenue (2026)

When a game studio enters a technopark, the first question is almost always: “Exactly which of my revenues does the exemption cover?” Game revenue is never a single line item — in-app purchases, in-game ads, store subscriptions, publisher royalties, even out-of-game consulting all interweave. The technopark exemption (Law 4691) does not treat them all the same. This piece separates the game revenue types one by one against the exemption.

Contents

• The logic: source of income, not its label
• Revenue type by revenue type
• The store cut: gross or net?
• Income that falls outside the exemption
• Comparison table
• Studio not in the zone: the Art. 10/1-ğ alternative
• FAQ

The logic: source of income, not its label

Provisional Article 2 of Law No. 4691 exempts earnings from software activity carried out in a technology development zone from corporate tax until 31/12/2028. The decisive phrase is “earnings arising from software activity.”

A game is, in law, a piece of software. So the real question is not “is this revenue in-app or ad-based?” but “does this revenue arise from a game developed in the zone?” If the source is in-zone software — whether the payment comes from Apple, Google, Steam or an ad network — the earnings fall within the exemption.

💡 Note from Gökay GÜL — CPA perspective: The most common mistake in game studios is classifying revenue by “payment channel.” The correct classification asks “which software does this attach to?” The in-app and the ad revenue of a game you develop in the zone go into the same exemption pool; consulting income from an out-of-zone engagement does not.

Revenue type by revenue type

In-app purchases (IAP). Purchases the player makes inside the game (coins, gems, battle pass, cosmetics). If the game is developed in the zone, this revenue arises from software → within the exemption.

In-game advertising (rewarded video, banner, interstitial). Revenue from ad networks (AdMob, Unity Ads, ironSource, etc.) derives from the game itself — the in-zone software → within the exemption.

Store / game subscriptions. A subscription offered by the game (VIP membership, monthly pass) again arises from the game → within the exemption.

Premium (one-time) game sales. Selling the game itself via Steam, the App Store or Google Play → within the exemption.

Publisher / licensing income. Royalties you receive when you license your game to a publisher or grant the IP to another platform — if grounded in software produced in the zone → within the exemption. But the contract must document that it is “a license of software produced in the zone.”

The store cut: gross or net?

Apple, Google and Steam take a commission from your game’s revenue (15% or 30% depending on store and program). A frequent confusion: is the exemption computed on gross revenue, or after commission?

The technopark exemption applies to earnings — not revenue. The store commission is a cost of sale; it is deducted from revenue and the remainder flows into the earnings calculation. So:

• Gross revenue (what the player paid) − store commission − other expenses = earnings
• The exemption covers 100% of these earnings (until 31/12/2028).

⚠ Risk warning: Treating the store commission as “revenue that never arose” rather than as an expense is an accounting error. Apple/Google reports show gross revenue and commission separately; your records must reflect gross revenue as income and the commission as an expense, and the VAT/withholding treatment must be built on the same split.

Income that falls outside the exemption

The exemption is limited to “software activity carried out in the zone.” The following stay outside:

1. Development carried out outside the zone. If part of the team works outside the zone, earnings from that activity are not exempt. The in-zone/out-of-zone split must be documented through payroll and cost allocation.
2. Services not directly tied to the game. General consulting, training or agency work provided to another firm does not arise from the in-zone game software.
3. Physical goods / merchandise. Selling game-themed T-shirts, figurines or books is not software earnings.
4. Interest, FX gains, incidental income. Financial income unrelated to zone earnings is assessed outside the exemption.

🎯 Strategic note for multinational groups: Within a group, in-zone (technopark) and out-of-zone activities can be placed in separate units; but revenue/cost segregation and transfer-pricing discipline are essential. Invoices issued to a foreign group company must be at arm’s length and structured to show they rest on software produced in the zone.

Comparison table

Revenue type	Exemption status	Condition
In-app purchases (IAP)	✅ Covered	Game must be developed in the zone
In-game advertising	✅ Covered	Revenue must arise from the in-zone game
Store subscription	✅ Covered	Subscription tied to the game
Premium game sales	✅ Covered	Sale of software produced in the zone
Publisher / licensing	✅ Covered	License of in-zone software must be documented
Store commission	— (expense)	Deducted from revenue, reduces earnings
Out-of-zone development	❌ Outside	Arises from out-of-zone activity
Consulting / agency work	❌ Outside	Does not arise from game software
Merchandise / physical goods	❌ Outside	Not software earnings

Studio not in the zone: the Art. 10/1-ğ alternative

A studio that does not enter a technopark and sells its games to a foreign player base can use the Corporate Tax Law Art. 10/1-ğ service-export deduction: 80% of the earnings from software services used abroad is deducted from the tax base. The effective burden is roughly 5% (the remaining 20 units × 25%).

The difference: Art. 10/1-ğ requires the customer/use to be abroad; the technopark does not care where the customer is, it requires the activity to be in the zone. If your game sells to both domestic and foreign players, the technopark is broader; if you sell entirely abroad and would rather not relocate into a physical zone, Art. 10/1-ğ is practical. See: Software Firms: Technopark or Service-Export Deduction?

FAQ

Does ad revenue count as “software earnings”? Yes — ad revenue arises from playing the game (the software) developed in the zone. Even though the ad network makes the payment, the source is the in-zone software; it falls within the exemption.

Steam takes 30%; which amount do I apply the exemption to? The exemption applies to earnings. The Steam commission is a cost of sale; it is deducted from gross revenue. 100% of the remaining earnings (until 31/12/2028) falls within the exemption.

I develop my game both in the technopark and outside. What happens? Only earnings from activity carried out in the zone are exempt. You must cleanly establish the in-zone/out-of-zone split through payroll and cost allocation; otherwise the exempt amount becomes contestable.

What if my exempt earnings exceed TL 5,000,000? For 2026, an obligation arises to channel 3% of the portion of exempt earnings above TL 5,000,000 into venture capital. A CPA (YMM) attestation report is also required.

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Action list

1. Classify your revenue lines by “which software they attach to” (not by payment channel).
2. Book the store commission as an expense; gross revenue ≠ earnings.
3. Separate in-zone from out-of-zone activity via payroll and cost allocation.
4. Track non-game income (consulting, merchandise) in separate accounts.
5. If exempt earnings exceed TL 5,000,000, plan the 3% fund + YMM attestation.
6. If you sell entirely abroad, compare the Art. 10/1-ğ alternative.

Related reading

• Turkey Technopark 2026: Foreign Investor Profit & Compliance Guide — the hub of this cluster
• A Foreign Game Studio’s Journey into Turkey
• Software Firms: Technopark or Service-Export Deduction?
• R&D Center or Technopark? 2026 Incentive Comparison

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This content is for general information; before applying it to a specific transaction, evaluate it with your CPA in light of current legislation and your company’s particular situation.

Gökay Gül — Certified Public Accountant (SMMM). Advises foreign investors and technology companies on company formation, incentives and tax planning in Turkey.