Date: 01 June 2026
Subject: New tax incentives for foreign investors, multinational corporate groups, exporters, service centres and individuals relocating to Türkiye
The application for an incentive certificate must be made before the investment begins. Expenditures incurred before the application date fall outside the scope of the incentive for most items.
Let us structure your investment within the scope of incentives
Our team manages incentive modelling, application, and compliance processes in line with your investment plan.
Important Note on the Current Legal Status
Two developments must be kept apart when reading Türkiye’s new investment and tax incentive framework:
- Presidential Decision No. 11257 was published in the Turkish Official Gazette (Official Gazette) on 30 April 2026. It increased the deduction available for profits derived from certain services provided from Türkiye to foreign recipients to 100%. This measure applies to income and profits relating to tax periods beginning on or after 1 January 2026.
- Law No. 7582 on the Amendment of Certain Laws was adopted by the Grand National Assembly of Türkiye (Türkiye Büyük Millet Meclisi – TBMM) on 21 May 2026. It was published in the Turkish Official Gazette of 4 June 2026, No. 33270, and is in force; individual provisions apply from the dates set out in its entry-into-force article (Article 14).
1. Overview
The new framework is designed to make Türkiye more attractive to foreign investors, multinational corporate groups, technology-oriented businesses and internationally mobile individuals.
The regime is not confined to conventional manufacturing investment. Taken together, the measures seek to position Türkiye as:
- a production and export base;
- a centre for high-value service exports;
- a regional management and coordination hub;
- a location for international trading and transit trade activities;
- a finance and operations hub through the Istanbul Finance Centre; and
- an attractive relocation jurisdiction for international investors and entrepreneurs.
Five elements matter most: the new regime for Qualified Service Centres (Nitelikli Service Merkezi); the incentives for transit trade; the reduced 12.5% corporate income tax rate for qualifying manufacturing activities; the 20-year exemption for foreign-source income of newly relocating individuals; and the wider range of incentives available within the Istanbul Finance Centre.
2. Key Changes Compared with the Initial Programme Announcement
| Initial Programme Announcement | Position under the Adopted or Confirmed Legal Framework |
| A 9% corporate income tax rate had been announced for manufacturing exporters. | The adopted text provides for a 12.5% corporate income tax rate for corporations holding an industrial registration certificate and actually engaged in manufacturing, in respect of income exclusively derived from manufacturing activities, as well as for qualifying agricultural production income. |
| A general 14% corporate income tax rate had been mentioned for exporters. | The adopted text does not contain a general 14% corporate income tax rate for exporters in that form. |
| Regional management centres were presented as a general incentive category. | The adopted text introduces the specific concept of a Qualified Service Centre, subject to defined statutory conditions. |
| The full tax benefit for certain service exports was still at the announcement stage. | A 100% deduction for profits from certain qualifying service exports has already been implemented through Presidential Decision No. 11257. |
| Tech Visa and digital incorporation were presented as core elements of the overall investment strategy. | These remain relevant to the broader investment environment, but they are not at the centre of the main tax incentive provisions introduced by Law No. 7582. |
3. Corporate Income Tax Rate of 12.5% for Manufacturing and Agricultural Production Activities
Under Law No. 7582 as adopted by Parliament, corporations that hold a Turkish industrial registration certificate and actually carry on manufacturing will be subject to a 12.5% corporate income tax rate on profits derived exclusively from that manufacturing activity.
The same rate will apply to corporate profits derived from qualifying agricultural production activities.
The provision applies to profits generated in tax periods beginning in 2027. For companies with a special accounting period, it applies to accounting periods beginning during the 2027 calendar year.
3.1. Significance for Foreign Investors
The new rate may be particularly relevant for foreign investors planning to establish or expand manufacturing capacity in Türkiye.
The incentive may be of interest in sectors including:
- textiles and apparel;
- automotive manufacturing and automotive components;
- machinery and equipment;
- electrical and electronic products;
- chemicals and plastics;
- food processing;
- defence industry; and
- advanced technology and industrial manufacturing.
3.2. Limitations and Practical Considerations
The 12.5% rate does not apply automatically to all of a company’s profits. It reaches only the profits attributable to the qualifying manufacturing or agricultural production activity.
A company with mixed activities — manufacturing, trading, exports and services — will therefore need accounting that separates qualifying from non-qualifying income reliably.
Profits taxed at the reduced manufacturing rate may not also benefit from the existing five-percentage-point corporate income tax reduction for export income. A company that both manufactures and exports should therefore work out which regime serves it better before it commits.
4. 100% Deduction for Certain Service Export Profits
Presidential Decision No. 11257, published in the Official Gazette on 30 April 2026, increased the deduction available for profits derived from certain services provided from Türkiye to foreign recipients to 100%.
This measure applies to tax periods beginning on or after 1 January 2026.
4.1. Potentially Qualifying Services
The regime may cover, in particular:
- architectural services;
- engineering services;
- design services;
- software development;
- medical reporting;
- bookkeeping services;
- call centre services;
- product testing;
- certification services;
- data storage;
- data processing;
- data analysis;
- certain vocational training services; and
- specified education and healthcare services subject to the relevant permits and supervision.
4.2. Principal Requirements
| Requirement | Explanation |
| Foreign customer | The service must be provided to individuals not resident in Türkiye or to entities whose statutory seat and place of effective management are outside Türkiye. |
| Use outside Türkiye | The service must be utilised exclusively outside Türkiye. |
| Qualifying service type | The activity must fall within the categories covered by the applicable legislation and implementing rules. |
| Transfer to Türkiye | The entire amount of the qualifying profit must be transferred to Türkiye by the deadline for filing the relevant annual income or corporate income tax return. |
| Separation of income | Domestic or otherwise non-qualifying income must be separately determined and documented. |
4.3. Practical Relevance
This measure may be particularly attractive for investors establishing a Turkish entity to provide services to foreign customers in areas such as:
- software development;
- engineering;
- data processing and analytics;
- international support and call centre operations; and
- medical or technical reporting.
The measure is not, however, a general exemption for international service activity. Eligibility turns on the nature of the service, the customer profile, the place where the service is utilised, the contractual and invoicing arrangements, and the timely transfer of qualifying profits to Türkiye.
5. New Legal Concept: Qualified Service Centre
For multinational corporate groups, one of the most significant innovations in Law No. 7582 is the Qualified Service Centre regime (Nitelikli Service Merkezi).
Under the adopted text, a Qualified Service Centre is a capital company established to provide services to related companies, or to a corporate group, actively operating in at least three different countries. At least 80% of its annual turnover must be generated from services supplied to related companies located outside Türkiye.
5.1. Basic Conditions
| Criterion | Requirement |
| Legal form | The centre must be incorporated as a capital company. |
| International group structure | The related companies or corporate group must be actively operating in at least three different countries. |
| Service recipients | Services must be provided to related companies located outside Türkiye. |
| Turnover threshold | At least 80% of annual turnover must be generated from services supplied to related foreign companies. |
5.2. Potential Activities
A Qualified Service Centre may perform functions including:
- financial advisory services;
- strategic management advisory services;
- risk management;
- cash and liquidity management;
- financing and debt coordination;
- investment and capital structure planning;
- budgeting, financial reporting and analysis;
- international accounting and compliance functions;
- audit and control activities;
- digital transformation and technology advisory services;
- data analysis and investment advisory services;
- human resources and training services;
- brand management and promotional coordination;
- after-sales support;
- technical support; and
- coordination of research and development, product testing and laboratory activities.
Where the services touch Turkish law or domestic legal matters, legal advice must comply with Turkish professional rules, and in particular must be given by lawyers or law partnerships authorised under the Turkish Attorneyship Act.
6. Tax Incentives for Qualified Service Centres
The adopted legislation provides for substantial corporate income tax advantages for Qualified Service Centres.
| Location of the Qualified Service Centre | Deductible Portion of Qualifying Profits |
| Qualified Service Centre generally operating in Türkiye | 95% |
| Qualified Service Centre operating in the Istanbul Finance Centre | 100% |
| Qualified Service Centre operating in certain industrial zones designated by the President | 100% |
The deduction applies only to profits earned from abroad through the qualifying activity.
A principal condition is that those profits be transferred to Türkiye by the deadline for filing the corporate income tax return for the accounting period concerned.
The incentive applies for 20 accounting periods from the accounting period in which the Qualified Service Centre commences operations. The relevant deductions are also available in the calculation of the tax base for Türkiye’s domestic minimum corporate income tax regime.
6.1. Income Tax Incentives for Qualified Personnel
Income tax relief is also available for qualified personnel who perform services directly within a Qualified Service Centre.
| Place of Employment | Tax-Exempt Portion of Remuneration |
| General Qualified Service Centre | Up to three times the gross minimum wage |
| Qualified Service Centre in the Istanbul Finance Centre | Up to five times the gross minimum wage |
| Centre in certain designated industrial zones | Up to five times the gross minimum wage |
Support and auxiliary staff will not be treated as qualified service personnel for these purposes.
6.2. Significance for International Corporate Groups
The regime may matter a great deal to multinational groups that want to centralise in Türkiye their regional functions for Europe, the Middle East, Central Asia, the Caucasus or Africa.
Potential centralised functions include:
- treasury and financing;
- international controlling;
- group reporting;
- compliance and risk management;
- technical support;
- procurement and supply-chain coordination;
- human resources and training; and
- digital transformation and data analytics.
Before implementing such a structure, a group should work through transfer pricing, the allocation of functions and risks, substance requirements, permanent establishment risks and the potential impact of the global minimum taxation rules.
7. Expanded Incentives for Transit Trade Activities
Law No. 7582 also introduces significant incentives for international transit trade activities.
It covers profits derived from buying goods abroad and reselling them abroad without importing them into Türkiye, and profits derived from acting as an intermediary in comparable trades in foreign goods.
| Location of Activity | Deductible Portion of Transit Trade Profits |
| General transit trade activity | 95% |
| Transit trade through the Istanbul Finance Centre | 100% |
| Transit trade in certain industrial zones designated by the President | 100% |
7.1. Conditions
The principal conditions are:
- the goods must not be brought into Türkiye;
- both the seller and the buyer must be located outside Türkiye; and
- the profit must be transferred to Türkiye by the deadline for filing the corporate income tax return for the relevant accounting period.
The rule applies to corporate profits relating to tax periods beginning on or after 1 January 2026, for tax returns required to be submitted from 1 July 2026 onwards.
7.2. Importance for Investors
This incentive may be relevant for:
- international trading companies;
- intra-group purchasing and distribution companies;
- commodity and goods trading companies;
- regional supply-chain management companies; and
- trading groups active between Europe, the Middle East, Central Asia and Africa.
In practice, the points that repay attention are the contractual structure, transfer pricing, banking arrangements, anti-money laundering compliance, beneficial ownership transparency, economic substance and any effect of the global minimum taxation rules.
8. Expanded Benefits of the Istanbul Finance Centre
Law No. 7582 also widens the existing incentive framework for the Istanbul Finance Centre.
| Area | New Incentive |
| Transit trade profits generated within the Istanbul Finance Centre | 100% deduction |
| Profits of a Qualified Service Centre operating in the Istanbul Finance Centre | 100% deduction |
| Income tax benefit for employees of a Qualified Service Centre in the Istanbul Finance Centre | Up to five times the gross minimum wage |
| Profit deduction for exported financial services | Extension of the existing temporary 100% deduction period until 31 December 2047. |
| Duration of the financial services export incentive | Extension until 31 December 2047 |
| Fee exemption for financial activities | Extension from five years to twenty years |
| Income tax benefits for employees | Extension of scope from financial institutions to all participants in the Istanbul Finance Centre |
The aim is to make the Istanbul Finance Centre attractive not only to banks and financial institutions, but also to the regional management, intra-group service, international trading and financing operations of multinational groups.
9. Twenty-Year Exemption for Foreign-Source Income of Newly Relocating Individuals
Law No. 7582 is directed not only at corporate investors but also at individuals considering relocating their tax residence to Türkiye.
An individual who becomes resident in Türkiye, and who had no residence and no disqualifying tax liability in Türkiye during the preceding three calendar years, will be exempt from Turkish income tax on income and gains derived outside Türkiye for 20 years.
The rule applies to persons becoming resident in Türkiye on or after 1 January 2026.
9.1. Principal Conditions and Consequences
| Topic | Rule |
| Eligible persons | Individuals newly relocating to Türkiye who had no residence or disqualifying tax liability in Türkiye during the preceding three calendar years |
| Scope of exemption | Income and gains derived outside Türkiye |
| Duration | 20 years |
| Turkish-source income | Continues to be taxed under the general rules |
| Certain previous Turkish income | Earlier tax liability arising from specified rental income, investment income or capital gains should not necessarily prevent access to the regime |
| Tax return treatment | Exempt foreign-source income will not be required to be included in an annual Turkish income tax return |
| Foreign taxes paid | Foreign taxes relating to exempt income cannot be credited against Turkish income tax |
| Subsequent failure to meet conditions | Taxes not collected may subsequently be assessed as tax loss if it is established that the conditions were not satisfied |
9.2. Inheritance Tax Benefit
Where a person benefiting from the regime dies during the 20-year exemption period, assets transferred through inheritance will be subject to a flat inheritance tax rate of 1%.
9.3. Practical Significance
The regime may be of particular relevance to:
- Turkish citizens living abroad;
- foreign entrepreneurs and investors;
- international founders;
- individuals holding foreign company participations, portfolios or dividend-generating investments;
- families with internationally structured wealth; and
- individuals considering relocating their residence and wealth management activities to Türkiye.
Before relocating, an individual should review tax residence, any exit taxation in the former country of residence, double taxation treaties, controlled foreign company rules, foreign trust or foundation structures, and succession planning.
10. Expanded Employee Share Incentives for Technology Startups
Law No. 7582 also broadens the tax advantages available for employee share participation arrangements in technology startups.
The relief applies to the benefit an employee receives on acquiring shares or equity interests free of charge or at a discount.
| Topic | Previous Framework | New Rule |
| Maximum tax-exempt amount | Employee’s annual gross remuneration | Employee’s gross remuneration for two years |
| Holding period required for full exemption | 12 years | 6 years |
If the shares are disposed of before the required holding period expires, tax is clawed back as follows:
| Time of Disposal | Clawback of Previously Exempt Tax |
| Within the first two years | 100% |
| Between two and four years | 75% |
| Between four and six years | 25% |
| After six years | No clawback |
This may matter to foreign investors and founders building technology-oriented businesses in Türkiye who want to attract or retain qualified employees through equity-based incentive plans.
11. Investor Guidance Table
| Investor Profile | Potential Incentive | Key Condition or Risk |
| Foreign company establishing manufacturing operations in Türkiye | 12.5% corporate income tax rate | Industrial registration certificate, actual manufacturing activity and proper segregation of income |
| Company providing software, engineering or data services from Türkiye to foreign customers | 100% deduction for certain service export profits | Qualifying service, use outside Türkiye and timely transfer of profits to Türkiye |
| Multinational corporate group | Qualified Service Centre regime | Active operations in at least three countries and at least 80% foreign related-party turnover |
| Regional purchasing or sales centre | 95% or 100% deduction for transit trade profits | Goods must not enter Türkiye, foreign parties and transfer requirement |
| Company operating in the Istanbul Finance Centre | 100% deductions and additional IFC benefits | Satisfaction of participant and qualifying activity requirements |
| Individual planning to relocate to Türkiye | 20-year exemption for foreign-source income | No disqualifying Turkish residence or tax status during the preceding three years |
| Technology startup | Tax-efficient employee equity participation | Proper structuring of the participation plan and compliance with holding periods |
12. Initial Review Questions for Clients
A. Companies and Corporate Groups
| Review Area | Key Question |
| Business model | Does the investment relate to manufacturing, service exports, transit trade or a regional service centre? |
| Selection of incentive regime | Would the manufacturing tax rate, service export deduction, Qualified Service Centre regime or establishment in the Istanbul Finance Centre be most beneficial? |
| Segregation of income | Can qualifying and non-qualifying income be reliably separated in the accounting records? |
| Transfer of profits | Can qualifying profits be transferred to Türkiye within the statutory deadline? |
| Location choice | Could establishment in the Istanbul Finance Centre or a designated industrial zone provide access to a 100% deduction? |
| Group structure | Does the corporate group meet the conditions for a Qualified Service Centre? |
| Transfer pricing | Are intra-group services and financing arrangements structured on an arm’s length basis? |
| Global minimum taxation | Could Pillar Two rules reduce or neutralise the economic benefit of the incentive? |
| Compliance | How will accounting, tax filings, beneficial ownership, AML and banking requirements be implemented? |
B. Individual Investors
| Review Area | Key Question |
| Tax residence | From what date would the individual be treated as resident in Türkiye? |
| Three-year condition | Did the individual have any disqualifying residence or tax status in Türkiye during the preceding three calendar years? |
| Source of income | Is the relevant income Turkish-source or foreign-source income? |
| Participation and portfolio structure | Would foreign dividends, participation income or portfolio gains fall within the exemption? |
| Succession planning | How could the 1% inheritance tax rate affect family wealth planning? |
| Foreign taxation | What taxation remains applicable in the source state or former state of residence? |
13. Legal and Tax Assessment
The new incentive framework materially changes Türkiye’s value proposition for foreign investors.
Earlier incentive models focused predominantly on manufacturing and exports. The new provisions expressly reach:
- regional management and support functions of multinational groups;
- international trade and supply-chain structures;
- high-value service exports;
- financial services;
- technology-oriented ventures; and
- the relocation of international investors and high-net-worth individuals.
Access to these benefits will not be automatic. In particular, investors will need to ensure:
- an appropriate corporate and tax structure;
- accurate separation of qualifying income;
- arm’s length structuring of intra-group transactions;
- timely transfer of qualifying profits to Türkiye;
- sufficient economic substance and personnel arrangements; and
- continuous monitoring of implementing regulations and administrative practice.
Large multinational groups should also test whether the benefit of a low effective Turkish tax rate would be partly neutralised by the international global minimum taxation rules, in particular Pillar Two.
14. Conclusion and Recommended Action
Türkiye’s new investment and tax incentive architecture is more than a package of individual tax reductions. It represents an attempt to reposition Türkiye as an international centre for manufacturing, service exports, regional corporate management, transit trade, financial services and qualified international capital.
An initial review is particularly worthwhile for:
- foreign companies planning manufacturing investments in Türkiye;
- companies intending to provide software, engineering, data or healthcare services from Türkiye to foreign customers;
- multinational groups seeking to centralise regional functions for Europe, the Middle East, Central Asia or Africa;
- international trading companies considering structuring transit trade or intra-group supply-chain operations through Türkiye;
- businesses assessing establishment in the Istanbul Finance Centre;
- individuals considering relocating to Türkiye and managing foreign-source income from Türkiye; and
- technology-oriented companies seeking to attract or retain qualified employees through equity participation arrangements.
Recommendation: No investment, relocation or restructuring decision should be taken before a tailored structuring analysis has been prepared for the client. That analysis should cover the business model, the appropriate corporate structure, the applicable incentive regime, the tax consequences, economic substance requirements, transfer pricing, the international tax implications, and the ongoing compliance obligations to be put in place.
