AUDIENCE 2 · OPERATIONAL + PRACTICAL
Turkey for Foreign Investors
For those considering Turkey operations: structure decision, tax-efficient setup, banking, capital flow — end-to-end.
Summary
Foreign-investor company formation in Türkiye has two timelines: MERSİS and Trade Registry filing, then post-registration bank KYC/AML and operational setup. An A.Ş. has minimum capital of TRY 250,000 and at least 25% of cash commitments is paid before registration; a Ltd. has minimum capital of TRY 50,000 and its cash capital may be paid within 24 months after registration. Apostille or consular authentication for foreign founder documents depends on the country and issuing authority. A bank account is not created automatically with registration and no fixed bank-completion date is promised. Law No. 4875 provides equal treatment while sector-specific permissions remain applicable. Technopark, Qualified Service Center and free-zone benefits are not automatic; each requires an activity and eligibility review. The Sistem Global Danışmanlık network can be coordinated where the scope calls for it, while Turkish registry and tax-accounting steps follow a licensed CPA control plan.
What we do
Structural Choice
JSC vs LLC by investment round, tax efficiency, and exit readiness.
Formation Operation
Tax number, MERSİS, capital and Trade Registry dossier, managed separately from the bank KYC timeline.
Bank Account Opening
KYC + UBO file prepared, right commercial segment selected.
Incentive Architecture
Technopark, R&D centre, Qualified Service Center and IFC — compared against their eligibility conditions.
Frequently asked
- 01What are the 7 critical steps to set up a foreign company in Turkey?
- 02JSC vs LLC for foreign investors — what is the difference?
- 03How does a foreign legal entity register through MERSIS?
- 04How long does capital deposit and bank account opening take?
- 05What is the E-TUYS investment notification form?
- 06What rights does Law No. 4875 grant foreign investors?
- 07What are the Qualified Service Center conditions and who can qualify?
- 08Which sectors require additional foreign capital permits?
AUDIENCE 2 · PERSONAL + CONFIDENTIAL
HNWI Advisory
Residency, wealth preservation, tax residency and succession planning for HNWIs considering Turkey or planning to exit.
Summary
Repeated Article 20/D of the Income Tax Code grants a 20-year income-tax exemption on foreign-source income to certain individuals deemed resident in Türkiye from 1 January 2026. The relief is not automatic: the prior-three-calendar-year domicile and tax-liability tests, a timely EK-1 Exemption Certificate and genuinely foreign-source income must all be established. Turkish-source income, corporate profits and source-country tax remain separate, so no single effective-tax outcome can be promised. Residency, treaty, banking, asset and corporate layers need one consistent evidence file.
What we do
Residency + Tax Residency
An Article 20/D eligibility file covering the residence date, prior three calendar years, EK-1 application calendar and source-of-income test.
Wealth Preservation
Holding + succession + treaty network combination.
Family Office Setup
Multi-generational wealth via global topology.
Confidentiality + Compliance
KYC, FATCA, CRS discipline + information-sharing posture.
Frequently asked
- 01Who can qualify for the 20-year exemption under repeated Article 20/D?
- 02What does Turkish citizenship mean for tax residency?
- 03How is the EK-1 Exemption Certificate deadline determined?
- 04Does transferring foreign income to Türkiye break the exemption?
- 05Why are Turkish-source income and corporate profit analysed separately?
- 06How is HNWI wealth-preservation structuring built in Turkey?
- 07What is the most tax-efficient succession path?
- 08How are source-country tax and treaty outcomes modelled?
AUDIENCE 2 · STRUCTURAL + LONG-TERM
Family Office Advisory
Structural tax planning and global topology coordination for multi-generational family wealth.
Summary
Family office structuring requires generational wealth management. In Turkey, the family office status is evolving as of 2026; existing regimes combine family holding + subsidiary structure + treaty network + succession discipline. In Europe, Estonia's distribution tax model favours passive family offices; Ireland's 12.5% CIT + IDA grant + IP holding is preferred; Malta and Cyprus offer low effective EU tax; Turkey suits operational subsidiaries. Pillar Two 15% minimum tax affects MNEs above €750M — mid-size family offices (€5-50M) are not actually triggered. The Sistem Global 15-country network coordinates topology while the Turkish CPA executes the Turkish subsidiary. Tax planning, succession and liquidity under a single hand.
What we do
Topology Design
15-country coordination — which layer in which country.
Succession Transfer
Tax-efficient structure + family constitution.
Liquidity Management
Exit scenarios + capital flow planning.
Compliance Management
CRS, FATCA, BEPS — international information sharing.
Frequently asked
- 01Under which status is a family office established in Turkey?
- 02Holding structure vs direct inheritance — what is the succession difference?
- 03Family office — Estonia / Ireland / Malta / Turkey comparison
- 04How does Pillar Two affect a family office?
- 05How is the treaty network used in family wealth distribution?
- 06How do SAFE / convertible instruments position in a family office structure?
- 07How is family constitution integrated with tax planning?
AUDIENCE 2 · OPERATIONAL + COMPLIANCE
Qualified Service Center (QSC) in Türkiye
For regional-management and group-service companies: eligibility, profit deduction, payroll and transfer-pricing controls under Law No. 7582.
Summary
The 2026 statutory answer to many legacy RHQ searches is Türkiye's Qualified Service Center (QSC/NHM) regime. A Turkish A.Ş. or Ltd. 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. A 95% corporate-profit deduction may apply only to foreign profit earned exclusively from QSC activities and transferred to Türkiye by the annual return deadline. The rate may be 100% for an IFC participant or a QSC in a presidentially designated Industry Zone. For qualified service personnel who directly perform listed work, excluding support staff, the exempt salary portion is capped at three times gross minimum wage generally and five times in the IFC or a qualifying Industry Zone. These are conditional deductions, not blanket exemptions. Profit segregation, intercompany agreements, arm's-length pricing and role evidence are essential. Pillar Two requires separate modelling for in-scope €750 million groups; the Sistem Global Danışmanlık network can be coordinated where needed.
What we do
Eligibility File
Evidence matrix for the three-country, related-group, activity and 80% revenue tests.
Profit and Repatriation
Segregation of QSC profit and the deadline-controlled Türkiye transfer file.
People and Payroll
Qualified-role mapping and three-times/five-times monthly cap control.
Pillar Two Management
QDMTT impact modelling and records for in-scope €750 million groups.
Frequently asked
- 01How is the QSC three-country condition evidenced?
- 02How is the 80% foreign-related-revenue test calculated?
- 03Which profits qualify for the 95% or 100% corporate deduction?
- 04What is the deadline for transferring QSC profit to Türkiye?
- 05Who is treated as qualified service personnel?
- 06How do the three-times and five-times payroll caps operate?
- 07Can QSC and IFC personnel regimes apply to the same employee?
- 08How do Pillar Two and QDMTT affect QSC profit?
