Eligibility File
Evidence matrix for the three-country, related-group, activity and 80% revenue tests.
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.
TL;DR — in 1 minute
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.
Frequently asked
- How is the QSC three-country condition evidenced?
- How is the 80% foreign-related-revenue test calculated?
- Which profits qualify for the 95% or 100% corporate deduction?
- What is the deadline for transferring QSC profit to Türkiye?
- Who is treated as qualified service personnel?
- How do the three-times and five-times payroll caps operate?
- Can QSC and IFC personnel regimes apply to the same employee?
- How do Pillar Two and QDMTT affect QSC profit?
Service scope for this profile
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.
Statutory basis and implementation
Sources checked: 8 September 2026
This page is for general information and does not replace professional advisory. Taxpayer-specific situations should be assessed in light of current legislation and your company’s circumstances.