Software Firms: Technopark or Service-Export Deduction? (2026)

For a company that develops software for foreign clients, sells SaaS, or provides remote engineering/design services, “tax advantage” usually brings the technopark to mind first. Yet there is another powerful lever you can use without entering any technopark: Article 10/1-ğ of the Corporate Tax Law — the service-export deduction. This article places the two routes side by side: which one fits which software firm?

Contents

• Two routes, two condition sets
• How the service-export deduction works
• Tax burden: two separate computations
• Comparison table
• Which software firm fits which?
• Can you use both?
• FAQ

Two routes, two condition sets

Technopark (Law 4691). Earnings from software activity carried out inside the zone are 100% exempt from corporate and income tax until 31/12/2028. In return: presence in the zone, channelling 3% of exempt earnings above the annual threshold set by Presidential Decree into a venture-capital fund, a CPA (YMM) attestation report where the SMMM-YMM communiqué thresholds are exceeded, and non-exempt treatment of activity outside the zone.

Service-export deduction (Corporate Tax Law Art. 10/1-ğ). Presidential Decree No. 11257 (Official Gazette 30/4/2026, No. 33239) set the rate at 100% for income and earnings of tax periods beginning on or after 1 January 2026. The statutory text still says 80%; that rate applies to 2025 and earlier periods. There is no zone requirement — it applies wherever your office is. In return come different conditions (below).

💡 Note from Gökay GÜL — CPA perspective: The distinction sharpens with one question: “Are my customers abroad or domestic?” If they’re all abroad and you’d rather not relocate into a physical zone, Art. 10/1-ğ is light and practical. If your customer mix is domestic-plus-foreign and your margin is high, the technopark may be stronger.

How the service-export deduction works

Art. 10/1-ğ lists its scope explicitly: architecture, engineering, design, software, medical reporting, bookkeeping, call center, product testing, certification, data storage, data processing and data analysis services rendered in Turkey to persons not resident in Turkey — or to those whose workplace or legal/business center is abroad — and used exclusively abroad. The deduction rate is 100% for tax periods beginning in 2026 and 80% for 2025 and earlier periods.

Three conditions are critical:

1. The customer must be resident abroad, and the service must be used only abroad. If the result is also used in Turkey, the deduction falls away.
2. The entire earnings must be repatriated to Turkey by the date the corporate tax return for that accounting period is due.
3. The invoice must be issued in the foreign customer’s name.

⚠ Risk warning: The label “software export” alone is not enough. SaaS offered to a Turkish company or to a user base resident in Turkey does not meet the “used exclusively abroad” test. Scope must be assessed on the contract and actual usage.

Tax burden: two separate computations

Let’s use numbers. Say 100 units of export earnings; the 2026 corporate tax rate is 25%.

• Service-export deduction (10/1-ğ): 100% of the earnings is deducted from the ordinary corporate tax base → 0 units of tax under the ordinary computation.
• Technopark (4691): Earnings 100% exempt → 0 units of tax (but the 3% fund obligation, YMM and zone costs apply).

Those two zeroes do not guarantee the same result. The Art. 10/1-ğ deduction cannot be subtracted from the domestic minimum corporate tax base; unless an exception such as the first-three-accounting-period rule applies, tax may still be payable. The technopark earnings exemption is among the items that can be subtracted from that minimum base. The technopark, however, carries zone rent, YMM attestation fees, the 3% fund transfer and compliance costs. Decide by running the minimum-corporate-tax computation as well as the ordinary computation.

Comparison table

Which software firm fits which?

Selling entirely abroad, small/agile team: Without relocating and without the 3% fund load, issuing invoices in the foreign customer’s name and repatriating earnings, working under Art. 10/1-ğ may be practical. But the 100% deduction zeroes the ordinary base; the domestic minimum corporate tax computation still has to be run separately.

High-margin, mixed domestic-and-foreign customers: Because the technopark’s 100% exemption works regardless of customer location, the technopark pulls ahead here — earnings from domestic customers also fall within the exemption (as long as produced in the zone).

R&D-intensive software with heavy payroll: The payroll income-tax withholding exemption of the technopark (and R&D center) does not exist under 10/1-ğ. If wage cost dominates, the technopark/R&D-center axis should be evaluated. (See R&D Center or Technopark?)

Can you use both?

The technopark exemption and the 10/1-ğ deduction apply to different earnings; you cannot make the same earnings advantageous twice. Earnings already exempt in the technopark are out of the base — you don’t stack the 10/1-ğ deduction on top. But export earnings from an activity unit outside the zone can be separately assessed under 10/1-ğ. This split must be cleanly set up in the accounts.

🎯 Strategic note for multinational groups: Within a group, it is possible to place in-zone (technopark) and out-of-zone (10/1-ğ) activities in separate units; but cost/revenue segregation and transfer-pricing discipline are essential.

Action list

1. Is your customer base abroad? (Yes → 10/1-ğ is possible; No → technopark axis.)
2. Is the service used exclusively abroad? Document the contract and actual usage.
3. Are invoices issued in the foreign customer’s name and earnings repatriated to Turkey?
4. Is your payroll cost heavy? If so, compare the technopark/R&D center for the withholding exemption.
5. Compare the zone cost + 3% fund + YMM total against both the ordinary and minimum corporate tax computations under Art. 10/1-ğ.

Related reading

• Turkey Technopark 2026: Foreign Investor Profit & Compliance Guide — the hub of this cluster
• R&D Center or Technopark? 2026 Incentive Comparison
• 100% Service-Export Deduction and Minimum Corporate Tax
• Turkey Technopark Net Incentive Calculator