Regulatory note: This article reflects the position as of 8 July 2026, based on subparagraph (20) added to Article 23 of Income Tax Law No. 193 by Law No. 7582 (Official Gazette 04.06.2026, no. 33270); supplementary Article 1 of Law No. 4875 on Foreign Direct Investments (the qualified service center definition); Art. 10/1-(j) of Corporate Income Tax Law No. 5520; and Income Tax General Communiqué No. 334 (Official Gazette 04.07.2026, no. 33300). The Ministry of Industry and Technology’s implementing regulation has not yet been issued; confirm the final rules for any specific transaction.

Qualified Service Center Payroll Exemption: A Guide to Communiqué No. 334

From 4 June 2026, Turkey offers multinational groups’ regional service centers a concrete payroll incentive: the portion of a qualified employee’s wage at a qualified service center (QSC) up to 3 times the gross minimum wage — up to TRY 99,090 per month in 2026 — is exempt from income tax. In the participant-certified Istanbul Finance Center the cap is 5×: TRY 165,150. Communiqué No. 334, published on 4 July 2026, drew the framework of the application; but this article is not here to retell the Communiqué. Every piece in the market repeats the same three examples. We will look at what the Communiqué does not say: how to manage the status while there is no regulation, what happens when the technopark incentive meets the same employee, and how much the payroll cost really drops for a foreign group.

60-second summary

The portion of a QSC qualified employee’s wage not exceeding 3× the gross minimum wage is income-tax-exempt — ITL Art. 23/1-(20), effective 04.06.2026.

For IFC participants and presidentially-approved industrial zones the cap is 5×: TRY 165,150 per month, TRY 1,981,800 per year.

The stamp duty exemption also applies to the exempt portion (wage stamp-duty rate 7.59 per mille); the excess is taxed under general rules.

QSC conditions are demanding: a capital company, serving a group active in at least 3 countries, with at least 80% of revenue from foreign related companies.

No STB regulation yet, no technopark/R&D overlap rule — the only double-benefit ban in the law sits on the IFC side (Law 7412 Art. 6/2).

What is a QSC, and who qualifies?

The qualified service center is defined in supplementary Article 1, added to Law No. 4875 on Foreign Direct Investments by Law 7582/6. Three conditions must be met at the same time:

Being incorporated as a capital company (a branch or liaison office cannot obtain the status),
Serving a related company or group of companies actively operating in at least three different countries,
Deriving at least 80% of annual revenue from related companies abroad.

The covered activities come in two clusters: (a) financial advisory, strategic management, risk management, cash and liquidity management, funding, budgeting, financial reporting, international accounting and compliance, audit, digital transformation, legal advisory, promotion, brand management, human resources and training, and their coordination; (b) the coordination and management of activities such as sales, after-sales support, technical support, R&D, external sourcing, product testing and laboratory services. A QSC is not a production center doing business on the group’s behalf; it is a management and expertise layer serving the group’s brain.

This definition gives, for the first time, a tax identity to the regional headquarters (RHQ) model that has long existed de facto in Turkey without a legal footing. The wage exemption is the payroll leg of the package; on the earnings leg, CITC Art. 10/1-(j) deducts 95% of the income the QSC earns exclusively from these activities from abroad (100% in the IFC and eligible industrial zones) from the corporate tax base — for 20 fiscal periods from the start of operations, provided the income is transferred to Turkey by the filing date. How this deduction collides with the global minimum tax for groups above EUR 750m is covered in detail in Turkey’s 100% QSC/IFC Exemption Meets Pillar Two; this article stays on the payroll side.

Two details form the heart of the structuring: the 80% revenue threshold is not a one-off formation condition but a living ratio — a single large domestic contract can break it. And the exemption attaches not to the company but to the nature of the employee: exempt and non-exempt employees sit side by side on the same payroll.

The mechanics of the exemption: the 3× / 5× cap and the excess portion

The wording of ITL Art. 23/1-(20) is clear: the exemption applies to the portion of the wage not exceeding three times the gross minimum wage. The 2026 gross minimum wage is TRY 33,030; the cap is TRY 99,090. For QSCs operating in the IFC with a participant certificate and QSCs in industrial zones the President deems eligible based on foreign-investment intensity, the multiplier is five: TRY 165,150. The President is authorized to reduce these multipliers down to one time and to raise them up to double — so 3× and 5× are not fixed; they can move by decree.

The “wage” covered by the exemption is broad: Art. 3 of Communiqué No. 334 counts, within the frame of ITL Art. 61, monthly salary, overtime, premiums, bonuses, expense allowances and all payments and benefits provided under whatever name as wages. The cap comparison is made against the monthly total gross, not item by item — an annual bonus paid in December inflates that month’s gross and creates an excess portion.

How the excess is taxed is the Communiqué’s most-confused point. Follow Example 2 of the Communiqué: for a qualified employee earning gross TRY 200,000 in July 2026, TRY 99,090 is exempt and the remaining TRY 100,910 is taxed under general rules. From the income tax calculated on this excess, the income tax attributable to the minimum wage is credited — once. Since the exemption already covers three times the minimum wage, applying the same credit a second time is out of the question. The remaining tax is declared and paid by the employer in the following month’s withholding and premium return (MUHSGK).

Stamp duty is an underrated line in payroll cost: under Art. 5/3 of Communiqué No. 334, the stamp duty exemption also applies to the portion exempted from income tax. The stamp duty rate on wages is 7.59 per mille (Stamp Duty General Communiqué No. 71, Official Gazette 31.12.2025, no. 33124, 5th repeated issue); for an IFC employee using the full 5× exemption this alone is worth TRY 1,253 per month.

Entry into force: under Art. 14/(ç) of Law 7582, the subparagraph took effect on the publication date — 4 June 2026. Wage payments for June 2026 and later can benefit; there is no retroactive application.

Payroll simulation: what do the numbers say?

T1 — 2026 exemption caps

Location	Multiplier	Monthly cap (TRY)	Annual cap (TRY)*
Standard QSC	3×	99,090	1,189,080
IFC (participant-certified) / eligible industrial zone	5×	165,150	1,981,800

* The annual figure is the monthly cap multiplied by 12 (arithmetic); monitoring is done monthly.

T2 — Payroll simulation (monthly gross)

Gross wage (TRY)	Location	Exempt portion (TRY)	Portion subject to income tax (TRY)	Monthly stamp-duty exemption (TRY)**
90,000	Standard QSC	90,000	0	683.10
150,000	Standard QSC	99,090	50,910	752.09
150,000	IFC	150,000	0	1,138.50
200,000 (Communiqué Example 2)	Standard QSC	99,090	100,910	752.09
250,000	Standard QSC	99,090	150,910	752.09
250,000	IFC	165,150	84,850	1,253.49

** Exempt portion × 7.59 per mille. The income-tax saving comes from removing the exempt portion from the progressive ITL Art. 103 schedule (15%–40%); the exact amount depends on the employee’s cumulative tax base, so the table gives no single schedule-dependent figure.

Simulation notes:

All rows use the 2026 gross minimum wage of TRY 33,030 (the TRY 33,075 figure seen in some secondary sources is a deviation; the Communiqué’s examples use 33,030).
The TRY 200,000 row is cross-checked one-to-one against Example 2 of Communiqué No. 334: excess portion TRY 100,910.
The table excludes employee/employer social security (SGK) contributions; the exemption works on income and stamp tax and does not touch SGK obligations.
The cap can change by Presidential decree (ITL Art. 23/1-(20), last sentence); the payroll parameter should be tied to decree monitoring.

Who is qualified personnel? The support-staff trap

The third paragraph of supplementary Art. 1 of Law 4875 draws the line in a single sentence: employees who directly perform the in-scope services and who fall outside support staff are qualified service personnel. There are two filters, and both must be passed at once:

Direct performance: The analyst actually producing the financial-reporting service is in scope; the same team’s administrative assistant is not.
Being outside support staff: Reception, security, drivers, office management and similar functions — whatever the title — are outside the exemption.

The grey zone is mixed roles. How does the exemption apply to a finance manager who spends part of the time on group reporting and the rest on Turkish domestic affairs? The Communiqué does not answer. The pro-rata approach voiced on Alomaliye — allocating by the in-scope share of time — is a reasonable interpretation, not a Communiqué provision; it stays at the “expected” level. Until the STB regulation is issued, there are two defensible paths for mixed roles: make the role exclusively in-scope through the contract and job description, or do not apply the exemption at all and reclaim it by amended return once things are clear. The middle road — undocumented de facto allocation — carries audit risk straight into the payroll.

One more warning: the qualified-personnel definition follows the work actually performed, not the hire date. If an employee shifts into a support function during the year, the exemption drops from that month; if the payroll service has no internal notification line to see it, the gap surfaces only in an audit.

Risk filter: what to do in the regulation vacuum?

T3 — Incentive comparison and overlap map

Criterion	QSC wage exemption	Technopark / R&D withholding incentive	IFC personnel incentive
Legal basis	ITL Art. 23/1-(20)	Law 4691 prov. Art. 2 / Law 5746 Art. 3	Law 7412 Art. 6/2
Mechanism	Income-tax exemption (the wage is born tax-free)	Cancellation of withholding (tax accrues, stays with the employer)	Income-tax reduction
2026 ceiling	TRY 99,090 / 165,150 per month	Per employee per month 40× = TRY 1,321,200 (Law 7555 + GITC 331)	Outside this article’s scope
Time limit	None in the sources	Time-limited regime tied to Law 4691 prov. Art. 2	Extended to 2047 by Law 7582/13
Combining with the QSC exemption on the same employee	—	NO rule (below)	BANNED (Law 7412 Art. 6/2, last sentence)

Read it as a decision matrix:

You are a QSC in the IFC and the employee uses the IFC income-tax reduction: ITL Art. 23/1-(20) does not apply to that employee. The sentence Law 7582 Art. 12 added to Law 7412 Art. 6/2 is explicit — this is the only double-benefit ban in the law. The election is made per employee: the 5× exemption or the IFC reduction? Depending on the wage level one of the two wins; run this math before the payroll is set up.
You are a QSC with employees in a technopark or R&D center: On combining the QSC exemption with the 4691/5746 withholding incentive on the same employee there is no statutory provision, no advance ruling, no official guidance — in none of the sources scanned as of 8 July 2026. Law 5746’s own anti-cumulation list (Art. 4/5) does not mention ITL Art. 23/1-(20); the subparagraph entered into force after that list. This is a finding of data absence, not a “it’s allowed” reading. Obtain an advance ruling (mukteza) from the Revenue Administration before applying; being the first taxpayer to stack both incentives without paper is an expensive experiment.
Status determination without a certificate: The STB procedural regulation has not been issued. There is currently no official registration mechanism for declaring “we are a QSC”; keeping the conditions (capital company, ≥3 countries, ≥80% foreign related-party revenue) provable by file is the only line of defense. Keep the transfer pricing report, the group organization chart and the revenue breakdown in the same folder.
Personnel seconded from abroad: The exemption applies to personnel employed at the QSC in Turkey; the position of staff whose payroll stays abroad and is recharged to Turkey sits in the interpretation layer and requires double-tax-treaty analysis — do not assume automatic exemption.
Wages near the cap: Premium and bonus months push the monthly gross above the cap. Monitoring is done month by month, not on an annual average.

Gökay GÜL’s Note: Have a separate exemption code opened in the payroll system for this exemption, and keep the qualified-personnel list versioned monthly, independent of HR — in an audit, the answer to “who was exempt, in which month, and why” must be readable from the payroll output. Second: measure the 80% foreign related-party revenue ratio at quarter closes, not at year-end. If the ratio slips below 80% in the third quarter, you still have a chance to brake domestic work or defer invoicing in the last quarter; if you notice it in December, you do not.

Field case: RHQ or QSC?

A European industrial group wanted, in the spring of 2026, to consolidate the finance, HR and procurement coordination of its Balkan and Middle East operations in a single hub; the shortlist was Dubai and Istanbul. When Law 7582 was published in June, the math changed. In the structure we built, the capital company established in Istanbul provides reporting and cash-management services to the group’s subsidiaries in seven countries; all revenue comes from foreign related companies. Of the eighteen-strong team, thirteen are qualified personnel directly performing the services and five are support staff. For the qualified team averaging around gross TRY 120,000, the exemption removed a TRY 99,090 base per person per month from taxation; in the group’s EUR-based comparison table, the net-to-gross spread of the Istanbul payroll became defensible against Dubai for the first time. The critical decision was this: the company could have moved into the IFC and taken the 5× cap, but the group already planned to use the IFC personnel reduction — under the Law 7412 Art. 6/2 ban the two would not combine on the same employees. We looked at the wage distribution: since most of the team stayed below TRY 165,150, the exemption was decisive even inside the IFC; the decision was to stay outside the IFC in the first year to reduce status risk and to reconsider moving once the regulation is issued. The incentive math is not a one-liner; the structural decision is built on top of the personnel distribution.

Frequently asked questions

1. When did the QSC wage exemption enter into force? On 4 June 2026 — the date Law No. 7582 was published in the Official Gazette (04.06.2026, no. 33270). Income Tax General Communiqué No. 334, which sets out the application procedure, was published on 4 July 2026 (no. 33300) and entered into force on publication.

2. How much is the monthly exemption in 2026? At a standard QSC, 3 times the gross minimum wage: TRY 99,090. In the participant-certified IFC and presidentially-approved industrial zones, 5 times: TRY 165,150. The wage portion above these amounts is taxed under general rules.

3. Can support staff benefit from the exemption? No. Supplementary Art. 1 of Law 4875 grants the exemption to employees who directly perform in-scope services and fall outside support staff. Administrative, cleaning, security and similar functions are out of scope regardless of title.

4. How is the wage portion above the cap taxed? The excess is taxed under the progressive schedule in ITL Art. 103; from the calculated tax, the income tax attributable to the minimum wage is credited once, and the remainder is declared and paid by the employer with the following month’s MUHSGK. The excess is also subject to stamp duty (7.59 per mille); the exempt portion is exempt from both taxes.

5. Is there a 20-year time limit on the wage exemption? No — the 20-fiscal-period limit belongs to the corporate-income deduction in CITC Art. 10/1-(j). The sources show no time limit for the ITL Art. 23/1-(20) wage exemption; but since the President may reduce the multipliers down to one time, the size of the exemption can change by decree.

Action list: how to apply the exemption in 6 steps

Status determination (now): Document the capital-company + ≥3 countries + ≥80% foreign related-party revenue conditions; gather the group chart, service agreements and revenue breakdown in one file. When the STB regulation is issued, calendar the application/registration step.
Qualified-personnel inventory: Screen job descriptions against the “direct performance” criterion; fix mixed roles by contract, and separate support staff from the list.
Payroll parameter: Have the exemption code defined with the 3× / 5× cap; verify the stamp-duty exemption applies to the same portion.
Monthly cap monitoring: Set up an automatic check comparing total gross to the cap in premium/bonus months; confirm the minimum-wage income-tax credit is applied once on the excess.
Filing: Declare the tax on the excess in the following month’s MUHSGK; if you are in the IFC, put the Law 7412 Art. 6/2 election per employee on written record.
Documentation and ruling: If any personnel overlap with the technopark/R&D incentive, obtain a ruling from the Revenue Administration before applying; measure the 80% ratio quarterly and assign decree/regulation monitoring to an owner.

Sources

Law No. 7582 Amending Certain Laws (Official Gazette 04.06.2026, no. 33270) — Arts. 5, 6, 7, 12, 13
Income Tax General Communiqué No. 334 (Official Gazette 04.07.2026, no. 33300)
Income Tax Law No. 193 Art. 23/1-(20); FDI Law No. 4875 supplementary Art. 1; Corporate Income Tax Law No. 5520 Art. 10/1-(j); IFC Law No. 7412 Art. 6/2
Stamp Duty General Communiqué No. 71 (Official Gazette 31.12.2025, no. 33124, 5th repeated issue)
Law No. 7555 (Official Gazette 24.07.2025, no. 32965) + Income Tax General Communiqué No. 331 — incentive ceiling
Alomaliye, Tepe YMM Circular 2026/147, Prozon 2026/198 — post-Communiqué secondary analyses

Gökay GÜL Certified Public Accountant (SMMM) | Director Partner, Sistem Global Danışmanlık 15+ years of field experience in company formation, incentive architecture and payroll compliance for foreign investors structuring into Turkey. For your QSC status assessment and payroll setup, book an appointment via gokaygul.com or write to info@gokaygul.com. Response within 48 hours.