Blog
Software Firms: Technopark or Service-Export Deduction? (2026)
Two routes for companies exporting software/SaaS from Turkey: the 100% earnings exemption inside a technopark (Law 4691), or deducting 80% of the earnings from the tax base via Corporate Tax Law Art. 10/1-ğ without entering any zone. 2026 conditions, effective tax burden and decision criteria.
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
- Effective tax burden: 5% vs 0%
- 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: physical presence in the zone, channeling 3% of earnings to venture capital (above the TL 5,000,000 exempt-earnings threshold for 2026), a CPA (YMM) attestation report, and non-exempt treatment of any activity outside the zone.
Service-export deduction (Corporate Tax Law Art. 10/1-ğ). 80% of the earnings from software services rendered abroad is deducted from the tax base. 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. 80% of the earnings from these activities is deductible.
Three conditions are critical:
- 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.
- The entire earnings must be repatriated to Turkey by the date the corporate tax return for that accounting period is due.
- 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.
Effective tax burden: 5% vs 0%
Let’s use numbers. Say 100 units of export earnings; the 2026 corporate tax rate is 25%.
- Service-export deduction (10/1-ğ): 80% of the earnings is deducted; the remaining 20 units are taxed at 25% → 5 units of tax. Effective burden roughly 5%.
- Technopark (4691): Earnings 100% exempt → 0 units of tax (but the 3% fund obligation, YMM and zone costs apply).
On paper the technopark yields lower tax; but once zone rent, YMM attestation fees, the 3% fund transfer and the compliance load are counted, Art. 10/1-ğ often offers a lighter total cost for a small/mid-size software firm selling entirely abroad.
Comparison table
| Criterion | Technopark (4691) | Service-Export Deduction (Art. 10/1-ğ) |
|---|---|---|
| Form of advantage | Earnings 100% exempt | 80% of earnings deducted |
| Effective CIT (on that income) | ~0% | ~5% |
| Zone requirement | Yes (physical) | No |
| Customer-location condition | None (produce in zone, sell to anyone) | Customer abroad + used abroad |
| Time limit | 31/12/2028 | Open-ended (permanent) |
| Fund obligation | 3% of earnings (above threshold) | None |
| CPA (YMM) attestation | Required (above threshold) | General audit; light extra condition |
| Payroll withholding exemption | Yes | No (not within this article) |
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 is the most practical route — ~5% effective, zero zone cost.
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.
FAQ
Does a SaaS subscription count as a “software service”? SaaS offered to a foreign customer and used exclusively abroad can fall within 10/1-ğ. What matters is where the use occurs and the invoicing/contract structure.
What if I don’t repatriate the earnings to Turkey? The deduction condition is breached. The entire earnings must be transferred to Turkey by the date the return is due.
If the technopark exemption ends in 2028, can I move to 10/1-ğ? Yes; 10/1-ğ is a permanent provision with no time limit. If your foreign-customer structure fits, a switch can be planned.
Action list
- Is your customer base abroad? (Yes → 10/1-ğ is possible; No → technopark axis.)
- Is the service used exclusively abroad? Document the contract and actual usage.
- Are invoices issued in the foreign customer’s name and earnings repatriated to Turkey?
- Is your payroll cost heavy? If so, compare the technopark/R&D center for the withholding exemption.
- Compare the zone cost + 3% fund + YMM total against the ~5% effective burden of 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
- Turkey Technopark Net Incentive Calculator
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.