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Qualified Service Center (QSC / NHM)

The current legal answer to legacy RHQ searches: eligibility, corporate-tax and payroll controls for group service centers under Law No. 7582.

Scope

The Qualified Service Center regime (QSC; Nitelikli Hizmet Merkezi or NHM), introduced into Foreign Direct Investment Law No. 4875 by Law No. 7582, is the current statutory framework behind many legacy “regional headquarters/RHQ” searches. A Turkish capital company must serve a related group actively operating in at least three countries, perform listed services and derive at least 80% of annual revenue from foreign related entities. The relief does not automatically cover all company income or every employee; activity, profit, repatriation, personnel and location conditions require separate evidence.

  • Statutory eligibility matrix — capital company, active group footprint in at least three countries and 80% foreign-related-revenue test
  • Activity map — finance, strategy, risk, budgeting, reporting, international accounting, technology, data, brand, HR and other listed coordination services
  • Intercompany agreements, service definition, invoicing and transfer-pricing control
  • Profit segregation — 95% deduction test only for foreign profit earned exclusively from QSC activities
  • Separate 100% deduction test for an IFC participant certificate or a presidentially designated Industry Zone
  • Evidence and calendar for transferring the profit to Türkiye by the annual corporate-tax return deadline
  • Role-based distinction between qualified service personnel and support staff
  • Payroll exemption — up to three times gross minimum wage at a standard QSC and five times in the IFC/qualifying Industry Zone
  • Ordinary income and stamp-tax treatment for excess salary and non-qualifying staff
  • Separate Pillar Two and Türkiye QDMTT modelling where the group is within the €750 million threshold

Process

  1. 01

    Pre-eligibility

    Country, related-party, activity and 80% revenue tests are checked against the statute.

  2. 02

    Entity and agreements

    A.Ş./Ltd. choice, service agreements, functions and risks, and transfer pricing are designed together.

  3. 03

    Evidence file

    Registry, tax, bank, IFC/Industry Zone and profit-transfer evidence is placed on a periodic control calendar.

  4. 04

    Tax return and payroll

    QSC profit is segregated from other income; qualified roles and monthly payroll caps are monitored.

Deliverables

  • QSC statutory eligibility and gap analysis
  • Three-country / related-party / 80% revenue evidence file
  • Service-agreement and transfer-pricing control matrix
  • Profit-segregation and Türkiye transfer calendar
  • Qualified-personnel role matrix and payroll-control template
  • Twenty-accounting-period conditions tracker

Pricing model

Quoted by group and country count, agreements/transfer-pricing scope, payroll footprint and any IFC/Industry Zone layer. Ongoing tax-return and eligibility monitoring is scoped separately.

Typical timeline

The statute does not prescribe one fixed “QSC approval time.” The schedule depends on whether an entity already exists, registry and bank work, group evidence, agreements and any IFC participant-certificate process.

Frequently asked

Are QSC and the legacy RHQ term the same?

RHQ is a market term for a regional-hub operating model. The statutory regime introduced in 2026 is the Qualified Service Center. A regional office is not automatically a QSC; the capital-company, three-country, related-party, listed-activity and 80% foreign-revenue tests must all be met.

Does a QSC automatically receive a zero corporate-tax rate?

No. The general rule is a 95% deduction for foreign profit earned exclusively from QSC activities. The rate may be 100% for an IFC participant or a QSC in a presidentially designated Industry Zone. Timely transfer of the profit to Türkiye and the other statutory conditions also apply.

Does the payroll exemption cover every employee and the full salary?

No. It covers qualified service personnel who directly perform listed services, excluding support staff. The exempt salary portion is capped at three times gross minimum wage at a standard QSC and five times in the IFC or a qualifying Industry Zone; the excess is taxed under ordinary rules. Stamp-tax exemption follows the income-tax-exempt portion.

Can Pillar Two affect a QSC?

Where the consolidated group is within the €750 million scope, low-taxed QSC profit requires separate Pillar Two and Türkiye domestic minimum top-up modelling. Payroll relief and the corporate-profit deduction sit on different tax bases, so the effect must be calculated from group data.

Related guides and tools

IFC and QSC 2026 guide Law No. 7582, the 95%/100% profit deduction, payroll relief and the IFC distinction. QSC payroll income-tax exemption Qualified-personnel definition, three/five-times caps and payroll examples. QSC, Pillar Two and QDMTT Minimum-tax effects of the corporate deduction at the €750 million threshold.

Official sources

Last statutory source check: 8 September 2026

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