RSUs From a Foreign Parent: The Tax That Lands Before the Cash, and the Social-Security Cost Nobody Mentions

Regulatory note — information cut-off: 31 July 2026. This article is based principally on: Articles 17, 61, 62, 63, 86, 94, 95, 96, 103 and 123, and repeated Articles 80 and 81, of the Income Tax Code No. 193; Articles 114, 371 and repeated Article 266 of the Tax Procedure Code No. 213; Income Tax General Communiqué No. 326 (Official Gazette 27.09.2024, issue 32675) and Communiqué No. 335 amending it (Official Gazette 04.07.2026, issue 33300); Law No. 7582 (Official Gazette 04.06.2026, issue 33270); Articles 80 and 82 of Law No. 5510 (Art. 80/1-(b) as amended by Law No. 7577); and the Stamp Tax Code No. 488.

Your shares under the parent company’s plan have vested and landed in your broker account. You have not sold; not a single lira has reached your hand. Yet your net salary dropped that month — or it did not change at all, and a letter arrived from the tax office a year later.

Turkish tax law treats the share your foreign parent gives you not as an investment but as salary, and it ties the earning of that salary benefit not to the sale but to the moment the share passes to you. Where the GVK Art. 17 exemption applies, the portion within the limit does not enter the income tax base at that stage.

Scope. This article addresses plans that actually result in delivery of shares (RSUs, free or discounted shares, stock options) and assumes a person who is a full taxpayer in Turkey and an employee on the payroll of a Turkish employer. In derivative or cash plans such as cash-settled RSUs, phantom shares and SARs, the taxable event and the characterisation may differ — those are out of scope. Establish first which category your specific plan falls into.

In 60 seconds

• Tax is not determined by the contractual “vesting” label alone; what matters is when legal and economic control over the share passes. In applying GVK Art. 17, Communiqué No. 326 Art. 3/2 takes the date the free share is delivered, or the date the discounted right is actually exercised. Depending on plan terms, these moments can diverge.
• Withholding or annual return — even where a group company hands shares directly to an employee on the Turkish subsidiary’s payroll, Communiqué No. 326 Art. 5/6-7 treats the benefit as salary paid “in any event” by the employer company; the Turkish employer runs payroll and withholds. Not recharging the cost does not move that duty onto the employee. GVK Art. 95/1 belongs to a separate structure in which the real employer genuinely is the foreign company.
• The new 2026 share exemption depends on the employer qualifying as a techno-entrepreneur under Ministry of Industry and Technology criteria. The Techno-Entrepreneur Badge is a strong instrument evidencing that status; it is not a separate condition named in the statute. The Turkish subsidiary of a multinational group generally cannot satisfy the independence test.
• Once the amount enters Turkish payroll (the withholding scenario), stamp tax also arises; the social-security premium is contested — if the share counts as a “benefit in kind”, Law No. 5510 Art. 80/1-(b) excludes it (analogy below).
• On sale the two-year rule does not operate, and there is no annual allowance. If a positive gain arises it is taxed from the first lira; a sale at a loss or without gain produces no tax.

Why “salary”? Because the statute says so

In defining salary, GVK Art. 61 does not stop at money: “…money and goods given in return for service, together with benefits capable of being represented in money that are provided.” The same article states that making the payment “under the name of a bonus, premium or otherwise” does not change its character.

Communiqué No. 326 Art. 3/1 ties that definition to shares for the purposes of applying the GVK Art. 17 exemption: share benefits granted by the employer free of charge or at a discount are treated as salary and taxed under the salary provisions. For a plan outside the exemption, the salary character is established directly through GVK Art. 61 and the concrete service relationship.

The measure of the base is repeated Art. 266 of the Tax Procedure Code (VUK) — the ordinary purchase-and-sale value of the share on the valuation date. A frequent citation error sits here: the Communiqué refers to repeated Art. 266, not to VUK Art. 267 (comparable value).

⚠️ DATA GAP — no valuation/exchange-rate method specific to shares. VUK repeated Art. 266 sets the measure (ordinary purchase-and-sale value on the valuation date); but there is no share-specific rule on which session price of a share traded on a foreign exchange applies, or at which rate it is converted into lira. This does not mean you may pick the price and the rate freely: the currency in which fair value is determined, and the general provisions under which it is converted to lira, must be established on the facts. Put your chosen method in writing, apply it consistently, and obtain a private ruling where the uncertainty is material.

The moment tax arises: four stops, two taxes

What the market calls “vesting” does not map onto the language the legislation uses. The Communiqué never says vesting; it says “the date of delivery” and “the date of acquisition”. The difference emerges when the moment the contractual vesting conditions are met separates from the moment the share actually passes into your control.

Communiqué No. 326 Art. 3/2, explaining the application of GVK Art. 17, draws a two-way distinction: for a free grant, the benefit is deemed earned as at the date the share is delivered; where a right to purchase at a discount is granted, as at the date the right is actually exercised. Art. 3/3 then sets the base — for a free grant, the whole fair value; for a discounted one, the difference between fair value and the price you paid. For plans outside the exemption these dates are a strong reference; but the taxable moment must be determined by reading GVK Art. 61 together with the legal- and economic-control tests, the plan agreement, and the actual delivery/access records.

The test is not merely an administrative view. In its decision of 3 December 2025 the Council of State’s Board of Tax Litigation Chambers separates earning into four stages: “…it is accepted as earned at any one of the stages of accrual, legal control, economic control and actual control.” The decision concerns a dentist’s professional income — it is not an RSU precedent, but it shows the judicial counterpart of the test.

The document defining the terms is the Ankara Tax Office Directorate’s private ruling of 8 May 2024: legal control is the income becoming claimable; economic control is the moment the income is placed at the disposal of its owner.

Table 1 — What happens at each of the four stops?

Who withholds? The Turkish employer’s responsibility governs

This is where most of the confusion sits. GVK Art. 94/1 lists those responsible for withholding and makes it compulsory on salary payments. GVK Art. 95/1 then creates an exception: the withholding method does not operate for “employees who receive their salaries directly from an employer in a foreign country”, and such persons declare their income by annual return.

The trap here is reading “employer in a foreign country” as “whoever the money comes from abroad”. GVK Art. 62 defines the employer: “Employers are the natural and legal persons who hire the employee and employ them under their orders and instructions.” If you are on the payroll of the Turkish subsidiary, that company is your employer — even if the parent delivers the share.

GVK Art. 96 ties withholding to payments made in cash or on account, and defines “payment on account” as the records and transactions showing the payer as indebted to the entitled party. For group share plans, Communiqué No. 326 as amended by Communiqué No. 335 makes that link expressly: Arts. 5/6-7 treat the benefit, where shares are delivered directly by other companies in the same group, as “salary paid in any event by the employer company”.

The payroll rule is not confined to the exemption. Communiqué No. 326 Art. 5/3 requires all shares given to employees by employers — whether or not within the scope of the exemption — to be shown on the salary payroll at fair value. The amount within the exemption appears on the payroll but does not enter the income tax base; the amount outside it is taxed under the salary provisions.

For that reason, in this article’s core case — a payrolled person hired by the Turkish subsidiary and working under its orders and instructions — the group company delivering the share directly, or not recharging the cost to Turkey, does not remove the Turkish employer’s payroll and GVK Art. 94/1 withholding responsibility. GVK Art. 95/1 is assessed in a separate employment structure in which the actual and legal employer genuinely is the foreign company and the Turkish company does not bear employer status; the payment channel merely being abroad does not produce that result.

Where it is contested whether the plan falls within the same group of companies, or who the real employer is, obtaining a private ruling from the Revenue Administration (GİB) on concrete documents provides strong protection. That uncertainty is not a reason to ignore a clear payroll obligation.

In a private ruling of 23 February 2012 directly concerning this plan structure — a share benefit from a foreign group company — the foreign group company was invoicing the share cost to the Turkish company. The administration treated the benefit as period salary income, because the employee was personnel of the Turkish company and the benefit was provided by reference to service conditions, and required the Turkish company to withhold and report it on the withholding tax return. The invoicing is a fact-specific element of that ruling and also supports the expense entry; it should not be read as the sole legal ground for the withholding outcome.

Table 2 — Who declares?

The approach that “the cost was not recharged, therefore the employee moves to GVK Art. 95/1” is wrong. Cost recharging matters for the expense and for intra-group accounting order; it is not a constitutive condition of payroll and withholding in a group plan where the Turkish company is the real employer. GVK Art. 95/1 belongs only to the separate set of facts in which the real employer is the foreign company.

⚠️ The safest route. Establish the real employer first. If the Turkish subsidiary hires the person and works them under its orders and instructions, put the group share on payroll at fair value — even if the cost is not recharged — and apply the withholding regime; where the Art. 17 conditions are met, keep the exempt amount outside the base separately. Consider GVK Art. 95/1 only where the real employer is the foreign company. Where the group perimeter or employer status is unclear, obtain a written private ruling from GİB.

”A new exemption has arrived” — but probably not for you

Article 3 of Law No. 7582 amended GVK Art. 17 and did two things: it raised the exemption ceiling from one times to two times annual gross salary, and it shortened the holding tiers. The wording of the amendment is clear — “three”, “four”, “six”, “seven” and “twelve” became “two”, “three”, “four”, “five” and “six” respectively. The implementing rules were written in Communiqué No. 335.

Most articles online still give the old tiers:

Table 3 — Holding tiers: before and after Law No. 7582

The tax clawed back is collected not from the employee but from the employer — without a tax-loss penalty, with late-payment interest.

⚠️ Application in time. The “regime in force” column above shows the tiers currently in the statutory text as at 4 June 2026. The 7582 amendment entered into force on that date and carries no express transitional or retroactivity provision. Accordingly, which holding tier applies on a later sale of shares acquired earlier under the exemption (particularly between 2 August 2024 and 3 June 2026) does not follow directly from the norm; for those shares, avoid firm periodisation and keep in view the need for a ruling or an implementation statement.

For shares given to employees free of charge or at a discount before 2 August 2024 there is no uncertainty: Communiqué No. 326 Art. 3/8 expressly provides that the GVK Art. 17 exemption cannot be used for them.

Communiqué No. 326 Art. 4/1 sets the exemption’s precondition: the company giving shares to its employees must qualify as a techno-entrepreneur company under criteria determined by the Ministry of Industry and Technology.

Those criteria were published on 3 July 2025. Article 5 of the Regulation on the Determination and Certification of Technology- and Innovation-Focused Ventures requires five conditions: being established in Turkey; holding SME status; being an independent enterprise under the SME Regulation; being no more than fifteen years old; and having a technology- or innovation-based, scalable business model.

The third condition usually closes the door. The SME Regulation (Presidential Decision No. 7297, Official Gazette 25.05.2023, issue 32201) assesses independence essentially by reference to capital and voting-rights relationships; where another enterprise holds 25% or more of the capital or voting rights, that enterprise is as a rule not treated as independent. There is an exception list to the 25% threshold — universities, qualified/institutional investors, venture capital companies and funds. A commercial parent company is not on that list.

If the foreign parent holds 25% or more of the Turkish subsidiary’s capital or voting rights, the subsidiary is as a rule not an independent enterprise — a strong obstacle to the badge and to the GVK Art. 17 exemption. Even so, the concrete shareholding/voting structure and the exceptions in the Regulation must be examined separately in each file. If you work at a Turkish company that does have techno-entrepreneur status the picture changes; I covered that scenario in Turkey’s 2026 ESOP turning point.

One further note: neither GVK Art. 17 nor the communiqués name the Techno-Entrepreneur Badge as a condition of the exemption. The statute says “criteria determined by the Ministry”; the Regulation sets out those criteria and their certification by the badge. The substantive conditions are therefore the criteria in Art. 5 of the Regulation; the badge is a strong implementing document showing they are met.

The real cost is not income tax alone

Gökay GÜL’s note: In these files the arithmetic usually starts with income tax; yet the same payroll line directly affects the social-security premium base and the stamp tax base too. Even if you cannot choose the month of delivery/acquisition, calculate in advance what that month will look like: see in one table which bracket the cumulative base moves into, how much room is left to the social-security ceiling, and the amount of stamp tax. Taking the plan calendar at the start of the year and modelling the three items on the same page reduces the post-payroll surprise.

The same event can raise three separate cost headings — but the three do not arise together in every file: income tax depends on how the amount is taxed, stamp tax on whether it enters Turkish payroll, and social security on the contested analogy above.

The cumulative base jump. The tariff brackets for salary income differ from those for non-salary income — GVK Art. 103 writes separate thresholds for salary. In 2026 the 27% band for salary runs from TRY 400,000 to TRY 1,500,000 and the 35% band from TRY 1,500,000 to TRY 5,300,000; the excess is 40%. A large benefit added to payroll in a single month pushes you into the upper bracket, and the effect does not stop with that month — your net salary falls for the rest of the year.

Withholding does not end the filing question. Even where the benefit has been taken onto Turkish payroll and withheld, if in 2026 the total of withheld salaries from a single employer exceeds the top-bracket amount in GVK Art. 103 (TRY 5,300,000), an annual return comes into play under GVK Art. 86/1-b. A large share benefit, combined with your ordinary salary, can cross that threshold on its own — seeing withholding on the payroll does not mean “no return”.

Social security. Law No. 5510 Art. 80/1-(b) keeps “benefits in kind” outside the premium base. The statute does not define a benefit in kind; the definition sits in the Social Security Institution’s Employer Transactions Circular No. 2020/20. For commemorative gold, the circular reasons: gold has a known daily value, is readily convertible into cash and is reflected on the payroll — therefore it is a cash benefit and subject to premium.

For a share traded on an exchange and freely disposable, that analogy grows stronger; but where there are restrictions such as a sale ban, a lock-up period or an insider window, the “readily convertible into cash” assumption weakens. Communiqué No. 326 Art. 5/3 requires shares to be shown on payroll at fair value regardless of whether they fall within the exemption. Being shown on the payroll is not by itself proof that the benefit is a cash benefit subject to premium.

⚠️ This is an analogy, not a ruling. As at the information cut-off date of 31 July 2026, no published Social Security Institution view specific to RSUs or share-based benefits could be verified in the official sources available for this study. On one side stands the “benefit in kind” exception in Law No. 5510 Art. 80/1-(b); on the other, the approach to a benefit with a known daily value that is readily convertible into cash. Assess the premium treatment together with the plan documents, transferability, sale restrictions and payroll structure, and obtain a written opinion from the SGK; this analogy alone does not settle either the taxable or the exempt outcome.

One current reference on the premium side: Law No. 5510 Art. 80/1-(b) was rewritten by Law No. 7577 of 2 April 2026. Confirm the rate of increase in the daily upper limit of earnings subject to premium from the current Art. 82 of Law No. 5510 and the Official Gazette before applying it. The frequently cited Art. 80/1-(d) allows the portion that could not be subjected to premium in a single month because the ceiling was exceeded to be added within the following two months — but on the statutory wording that carry-over is for payments “other than salary”. Whether that rule applies once the share benefit counts as “salary” depends on the premium character of the benefit; it should not be assumed automatically.

Stamp tax. When a Turkish employer takes the amount onto the salary payroll (the withholding scenario), the salary amount entering the payroll also enters the stamp tax base; the proportional rate applied to salaries is 0.759% (Stamp Tax Code No. 488, table (1) IV/1-b) — confirm the rate and the maximum amount applied per instrument from a current official source before the transaction. In the pure scenario where you receive the benefit directly from the foreign parent and declare it yourself by annual return under GVK Art. 95, there is no Turkish salary payroll, so this payroll-linked stamp tax does not arise. Note: instruments presented in Turkey, such as the plan agreement or an acceptance form, may give rise to stamp tax in their own right and must be examined separately.

From the field: the shares arrived, nobody looked at the payroll

Illustrative example. The situation below is a composite distilled from files frequently encountered in advisory practice; it does not describe a single real taxpayer.

A vesting of a few hundred shares had been sitting in the account for two years; unsold, with no counterpart on the payroll. Their owner is a product manager at the Turkish subsidiary of a software group: “Nothing came from the tax office, so I did nothing.”

In files of this kind the answer often received from the finance function is this: the parent did not invoice the plan cost to Turkey, and there is no entry in the accounts or on the payroll. The employee’s natural question follows — “If the company did not pay for it, what is there to show on the payroll?” Yet if the Turkish subsidiary is the real employer, the group company delivering the share directly or not recharging the cost does not displace the payroll and employer-salary outcome in Communiqué No. 326 Arts. 5/3 and 5/6-7. The missing entry is corrected on the employer’s side.

The matter is therefore examined along two lines. First, the employer side: the salary payroll, withholding and related returns that ought to have been applied are determined; where a deficiency is found it is corrected, and for past periods the conditions of VUK Art. 371 are assessed separately. Second, the employee’s annual return: if the 2026 total of withheld single-employer salaries exceeds the top-bracket amount in GVK Art. 86/1-b (TRY 5,300,000), an annual return is also filed and the taxes withheld are credited. In a structure where the actual employer genuinely is the foreign company and the withholding regime does not apply, GVK Art. 95/1 is assessed separately.

In the second limb it also happens that fair value cannot be established at the first attempt: if the exchange on which the share trades is closed for a public holiday on the vesting day, there is no closing price. In such a case the previous trading day’s close and the Central Bank buying rate for the same day may be taken as the basis and the reasoning recorded in the file — do not treat this as the single correct method fitting every file; the acquisition day, the price source and the exchange-rate choice must each be justified against the plan documents. In this type of file, the schedule showing the date, quantity and price on the day for each vesting should be requested from the company on day one.

When you sell: the two-year exemption does not, as a rule, apply to foreign parent shares

GVK repeated Art. 80/1, while treating gains from the sale of securities as capital gains, leaves two groups outside: “…excluding those acquired without consideration and shares belonging to full-taxpayer corporations held for more than two years…”

Two consequences follow.

First, the two-year exemption is granted only to shares of full-taxpayer corporations. If the foreign parent is a limited-taxpayer foreign corporation with neither its legal nor its business centre in Turkey — as is generally the case in an ordinary multinational structure — you cannot use that exemption however long you hold the share. (Confirm the corporation’s Turkish tax status nonetheless.)

Second, a common misreading. A share being given free of charge does not mean it was “acquired without consideration” in the legislative sense: the consideration here is the employee’s labour. That is precisely why the benefit counts as salary. Where there is a genuinely gratuitous transfer entirely independent of the service relationship, the without-consideration exception in GVK repeated Art. 80 is assessed separately on the concrete facts; it does not apply automatically to an employee share plan.

Repeated Art. 81 governs the computation of the gain: the net capital gain is found by deducting from the disposal proceeds the indexed acquisition cost and the expenses borne and taxes/duties paid by the seller (such as the foreign broker’s sale commission and transaction costs directly linked to the sale). The acquisition cost is increased by the rise in the producer price index, excluding the month of disposal — but only if that rate of increase is 10% or more. So compute the tax not on “sale − cost” but after deducting these expense items too; otherwise the tax comes out higher than it should.

And a frequent error: the annual capital-gains allowance does not operate here. In granting the allowance, the relevant paragraph of repeated Art. 80 says “excluding those derived from the disposal of securities and other capital market instruments”. So if a positive net capital gain arises on sale it enters the return from the first lira (no annual allowance); if the sale does not exceed cost, no tax arises.

⚠️ DATA GAP — acquisition cost. Within the scope of this study, no published administrative view or judicial decision could be verified that directly states that the fair value taxed as salary at vesting will be treated as the acquisition cost on sale. The 2012 ruling does not address the employee’s later sale; nor does Communiqué No. 326 contain a provision on acquisition cost upon disposal. The scheme of the statute supports that outcome — otherwise the same amount is taxed twice — but the administration has not yet confirmed it.

The practical consequence of that gap is severe. Repeated Art. 81 provides that where the acquisition cost of a security cannot be substantiated, the nominal value in Article 266 of the VUK is taken as the acquisition cost; that is the share’s par value, and for US shares it is often below one cent. In other words, if you cannot substantiate your cost with documents, the gain approaches almost the entire sale price — a heavy evidentiary risk. (The fall back to par value follows from the wording of repeated Art. 81; it should nonetheless be assessed against the specific share type and documents.)

Communiqué No. 326 Art. 5/3 requires shares given by employers to be shown on the payroll at fair value regardless of whether they fall within the exemption. The payroll record is one of the core documents in your cost-substantiation file on sale — but it is not sufficient on its own: it must be kept together with the plan agreement, the grant/vesting/settlement documents, the broker statement, and the transaction date/quantity/price with the exchange-rate computation. If it does not appear on the payroll, deal with it today; do not start looking on the day of the sale.

If a withholding was made in the US, Article 23 of the Turkey-US Double Taxation Treaty and GVK Art. 123 may permit a credit — but not automatically; two questions must be answered first.

First question — does the US have the right to tax this salary? DTT Art. 15/1 governs dependent personal services: if the service is performed in Turkey, the US as a rule has no right to tax that salary. If a payrolled employee of the Turkish subsidiary does their work in Turkey, the parent withholding tax in the US does not make that income creditable.

Even where part of the service is performed in the US, a US taxing right does not arise automatically. If the three conditions in DTT Art. 15/2 are met together, the salary is taxable only in Turkey: the employee must not exceed 183 days in the US in aggregate in any continuous twelve-month period; the payment must be made by or on behalf of an employer who is not a US resident; and the salary must not be borne by a permanent establishment or fixed base in the US.

If one of those conditions is not met, the US may tax the portion attributable to the service performed there. A credit only arises for that portion which may also be taxed in the US under the Treaty, and subject to the documentation/limit conditions in GVK Art. 123.

Exception: if you are a US citizen or treated as a US resident, the treaty’s saving clause permits the US to tax you on your worldwide income; the credit relationship is assessed separately.

Second question — are you within the new-resident exemption? Repeated Art. 20/D of the GVK, introduced by Law No. 7582, provides that taxes paid abroad on income within its scope cannot be credited in Turkey. That provision applies, under Art. 14/(a) of Law No. 7582, only to persons deemed to have settled in Turkey from 1 January 2026. In addition, the person must have had neither a residence nor tax liability in Turkey in the last three calendar years before settling. If those two temporal conditions are met, check whether the benefit falls within the scope of repeated Art. 20/D before moving to a credit.

After those two questions are answered affirmatively: only source-country tax in the nature of income tax eligible for credit is credited, satisfying the documentation conditions in GVK Art. 123 (a document obtained from the competent authority and certified by the Turkish embassy or consulate). The credit is limited to the Turkish tax attributable to the foreign income.

Action list

A facts-first checklist. The variables that determine the outcome: (1) are you a full taxpayer in Turkey; (2) do you have a payroll relationship with a Turkish employer; (3) is the plan share-settled or cash-settled; (4) does the employer hold the techno-entrepreneur badge; (5) does the parent recharge/invoice the cost to Turkey; (6) what is the parent’s capital/voting-rights ratio in the subsidiary. Until those six answers are settled, the tax outcome is not settled either.

1. Check your payroll today. In the vesting months, does the fair value of the share appear on the payroll? Communiqué No. 326 Art. 5/3 makes this expressly compulsory, whether or not it falls within the exemption. A missing entry is a risk both for the current tax liability and for future cost substantiation.
2. Ask the plan administrator for a regular schedule. For each vesting: date, quantity and the price on the day; within ten days of vesting.
3. Determine your fair-value and exchange-rate method on the concrete facts under the general valuation/exchange-rate provisions, and put it in writing. Which exchange, which session, which rate — consistency is essential but not sufficient on its own; since there is no express share-specific exchange-rate rule, justify the method and obtain a ruling where uncertain.
4. Clarify whether the cost is recharged. That information matters for the expense, transfer pricing and intra-group accounting order; it is not the element determining the existence of payroll and withholding where the Turkish company is the real employer. Handle the group share benefit within Turkish payroll and withholding; where the real employer or the group perimeter is contested, obtain a ruling from GİB.
5. Review past periods. The employee’s annual income tax return and the employer’s correction of the withholding/premium service return are different things; voluntary disclosure does not by itself resolve a misclassified withholding responsibility. For VUK Art. 371 the event must not previously have been reported by a proper denunciation; it must be self-reported before an examination begins for the relevant tax type or the matter is referred to the assessment commission. A return never filed must be filed within 15 days of the report date; an incomplete/incorrect declaration must be completed or corrected, and the tax together with the voluntary-disclosure surcharge paid within the same period. Where the conditions are met, correction by voluntary disclosure may be considered. The assessment limitation period is as a rule five years under VUK Art. 114; for the clawback of the GVK Art. 17 exemption, the special starting point must also be taken into account.
6. Compute the total burden together. See income tax, the social-security premium and stamp tax not separately but together on the same month’s payroll.

Sources

• Income Tax Code No. 193 — Arts. 17, 61, 62, 63, 86, 94, 95, 96, 103, 104, 123; repeated Arts. 20/D, 80, 81
• Tax Procedure Code No. 213 — Arts. 114, 262, 371; repeated Art. 266
• Income Tax General Communiqué No. 326 (Official Gazette 27.09.2024, 32675) and Communiqué No. 335 amending it (Official Gazette 04.07.2026, 33300)
• Law No. 7524 (Official Gazette 02.08.2024, 32620) Art. 2 · Law No. 7582 (Official Gazette 04.06.2026, 33270) Art. 3
• Income Tax General Communiqué No. 332 (Official Gazette 31.12.2025, 33124, 5th repeating) — 2026 tariff
• Regulation on the Determination and Certification of Technology- and Innovation-Focused Ventures (Official Gazette 03.07.2025, 32945) Art. 5
• Regulation on Small and Medium-Sized Enterprises (Presidential Decision No. 7297, Official Gazette 25.05.2023, 32201) Arts. 6, 8, 9, 10
• Law No. 5510 Art. 80 (as amended by Law No. 7577, Official Gazette 17.04.2026, 33227) and Art. 82 · SGK Employer Transactions Circular No. 2020/20
• Stamp Tax Code No. 488, table (1) IV/1-b
• Turkey-US Double Taxation Treaty Arts. 13, 15, 23
• GİB private rulings: B.07.1.GİB.4.34.16.01-GVK 61-724 (23.02.2012) · E-38418978-120[61-2023/7]-249288 (08.05.2024) · 84098128-120.07.01[Mük.80-2015-2]-408 (03.09.2015)
• Council of State, Board of Tax Litigation Chambers, E. 2024/566 K. 2025/982 (03.12.2025) — the earning doctrine