Law No. 7582 “On Amendments to
Certain Laws” was Published in the Official Gazette
Law No. 7582 “On Amendments to
Certain Laws” was published in the Official Gazette dated June 4, 2026, and
numbered 33270.
Under this Law:
- In the application of deferring public receivables under Article 48 of Law No. 6183, where the conditions specified therein are met, the maximum deferral period is increased from 36 months to 72 months, and the amount of debt that can be deferred without collateral is increased from 250,000 TL to 1,000,000 TL,
- For those meeting the exemption criteria set forth in the proposed “Repeated Article 20/D” to be added to the Income Tax Law No. 193, the Inheritance and Gift Tax rate shall be applied at 1% for property transfers occurring through inheritance within the prescribed period,
- Increasing the tax exemption limit for shares granted free of charge or at a discount to employees by techno-initiative meeting the criteria set by the Ministry of Industry and Technology to twice the annual gross salary, and revising the deadlines for collecting taxes not paid on time based on the holding periods of the shares,
- Under the proposed “Repeated Article 20/D” to be added to the Income Tax Law No. 193, income and earnings derived outside Turkey by individuals deemed resident in Turkey, provided they do not have a residence or tax liability in Turkey for a period of 20 years,
- By adding “Transitory Article 1” to the Foreign Direct Investment Law, defining the term “qualified service center,” and providing an income tax exemption for companies that meet the criteria for a qualified service center regarding the wages of employees they hire at these centers, and granting a corporate tax deduction under the Corporate Tax Law for profits earned abroad by institutions operating as qualified service centers,
- Setting the exemption rate at 95% for profits derived from the sale of goods purchased from abroad to another country without being imported into the country (without being nationalized) or from acting as an intermediary in goods transactions conducted abroad, (100% for entities operating in industrial zones established under the Industrial Zones Law No. 4737 and deemed appropriate by the President based on the concentration of foreign investment, as well as for entities operating in the Istanbul Financial Center Zone under the Istanbul Financial Center Law No. 7412 after obtaining a participant certificate) , and to allow for the deduction of such tax-exempt income from the domestic minimum corporate tax,
- The corporate income tax rate shall be set at 12.5% for profits derived exclusively from production activities by entities holding an industrial registry certificate and actually engaged in such activities, as well as for profits derived exclusively from agricultural production activities by entities engaged in such activities,
- Regulations should be established to allow deductions for transit trade, qualified service center, and financial services export income from the minimum corporate tax base,
- A new asset amnesty regulation should be implemented, allowing unrecorded cash, gold, foreign currency, securities, and other capital market instruments—whether located abroad or within the country—to be declared and held in term accounts, in government domestic debt securities issued under Law No. 4749, lease certificates, or venture capital investment funds, and allowing such assets to be brought into Turkey,
- If unregistered securities or cash assets—regardless of whether they are located domestically or abroad—are reported to a bank or brokerage firm and transferred by July 31, 2027, they will be taxed at a rate between 0% and 5% (depending on the commitment period for holding Government Debt Securities or Lease Certificates), ensuring their registration,
- A regulation should be enacted stipulating that the provisions of the Turkish Commercial Code regarding conditional capital increases shall not apply to conditional capital increases conducted by non-publicly traded companies holding the “techno-initiative” badge issued by the Ministry of Industry and Technology, based on convertible debt agreements,
- A regulation should be enacted to expand the income tax deduction currently provided to financial institutions in the Istanbul Financial Center—which applies when employing personnel with international experience—to cover all participants,
- Regulations have been enacted to extend the duration of the 100% tax exemption applied to profits derived from the export of financial services by institutions located in the Istanbul Financial Center until 2047, and to extend the exemption period from financial activity fees for participating financial institutions to 20 years,
Regulations have been enacted
regarding these matters
Deferral/Installment Periods
Under the Law on the Collection of Public Debts and the Increase in the Amount
of Debt Eligible for Unsecured Installment Plans
Article 1 of the
aforementioned Law extends the deferral/installment period for public debts
from 36 months to 72 months and increases the debt amount eligible for
unsecured deferral/installment plans from 250,000 TL to 1,000,000 TL.
With this amendment, it is now
possible to defer and installment-pay debts up to a total of 1,000,000 TL
(including this amount) per creditor collection office for up to 72 months
without requiring collateral.
The relevant provision entered
into force on June 4, 2026, the date of publication of the Law.
Application of Reduced Rates
in Inheritance and Gift Tax
Pursuant to Article 2 of the
aforementioned Law, a paragraph has been added following the second paragraph
of Article 16 of the Inheritance and Gift Tax Law No. 7338; a provision is
established to apply a 1% inheritance and succession tax rate to assets transferred
by inheritance that are subject to inheritance and succession tax, provided
that the income and profits derived from sources outside Turkey are exempt from
income tax, and this exemption is in effect during the period in which the
aforementioned exemption is utilized.
The aforementioned provision
entered into force on June 4, 2026, the date of publication of the Law.
Wage Exemption for Techno-Initiative
Employees’ Acquisition of Stock
Article 3 of the
aforementioned Law amends the wage exemption currently applied to company
shares of a wage nature that are granted to employees by employers qualifying
as techno-initiative—in
accordance with criteria established by the Ministry of Industry and
Technology—either free of charge or at a discount.
Accordingly, the upper limit
of the exemption amount is increased from one year’s gross salary to twice one
year’s gross salary. In cases where shares of a salary nature acquired in this
manner are disposed of by the employee within the specified periods, the
exemption amount is recovered along with late payment interest without the
application of a tax evasion penalty; if the shares are disposed of within 3
full years from the acquisition date, the period for recovering the full amount
of the exempted tax is 2 years; if disposed of between 4 and 6 years from the
acquisition date, the period for recovering 75% within 3 to 4 years, and if the
property is disposed of between 7 and 12 years from the acquisition date, the
period for recovering 25% of the exempted tax is reduced to 5 to 6 years.
Consequently, while the upper
limit of the applicable exemption is increased by onefold, the regulation
regarding the recovery of a certain portion of the exempt amount upon the
disposal of shares acquired at a discount or for free encourages the
application of the exemption by shortening the holding periods.
The provision in question
entered into force on June 4, 2026, the date of the Act’s publication.
Application of the Income Tax
Exemption for Foreign Earnings
Pursuant to Article 4 of the
aforementioned Law, a new Article 20/D titled “Tax Exemption for Earnings and
Income Derived from Abroad” has been added following Article 20/C of the Income
Tax Law No. 193; Effective January 1, 2026, an income tax exemption for a
period of 20 years has been introduced for foreign-sourced income of
individuals deemed to be resident in Turkey, provided they have not had a
residence or tax liability in Turkey during the preceding three calendar years.
For individuals covered by
this provision, the existence of tax liability in Turkey prior to falling under
this scope—due to real estate capital income, movable capital income, or
capital gains—will not preclude them from benefiting from this exemption. No
annual tax return will be required for these income and earnings; furthermore,
even if a tax return is filed for other income, these specific income and
earnings will not be included in the return. Expenses and costs related to the
exempt income and gains shall not be taken into account in determining taxable
income and gains. Taxes paid in foreign countries on income and gains covered
by this exemption shall not be offset against the income tax assessed in
Turkey.
This provision entered into
force on June 4, 2026, the date of publication of the Law, and applies to
individuals deemed to be resident in Turkey as of January 1, 2026.
Wage Exemption for Qualified
Service Center Employees
Article 5 of the
aforementioned Law introduces a wage exemption for qualified personnel employed
in qualified service centers as defined under the Direct Foreign Investors Law.
Pursuant to the provision
added to the first paragraph of Article 23 of the Income Tax Law regarding wage
exemptions, the portion of wages paid to qualified personnel employed in
qualified service centers defined under the Direct Foreign Investors Law, up to
three times the gross minimum wage, is exempt from income tax.
For industrial zones
established under the Industrial Zones Law No. 4737 dated January 9, 2002,
those deemed appropriate by the President based on the zone’s foreign
investment density, as well as qualified service centers operating in the
Istanbul Financial Center with a participation certificate, the exemption will
apply up to five times the gross minimum wage.
This provision entered into
force on June 4, 2026, the date of publication of the Law.
Redefinition of the Qualified
Service Center Model
Article 6 of the
aforementioned Law amends the definition of “Qualified Service Center”
contained in Article 1 of the Annex to the Direct Foreign Investment Law No.
4875.
Qualified service centers are
defined as capital companies operating in at least three countries and deriving
at least 80% of their annual gross revenue from abroad.
The services provided by these
centers are defined as follows:
“a) Financial consulting,
strategic management consulting, risk management, cash and liquidity
management, financing and borrowing transactions, investment and capital
structure planning, budgeting, financial reporting and analysis, international
accounting and compliance, auditing, digital transformation and technology
consulting, investment and data analysis, legal consulting (Legal advisory
services related to domestic operations or Turkish law may only be provided by
an attorney or law firm authorized under the Attorney’s Act No. 1136 dated
March 19, 1969), marketing, brand management, human resources and training
services, as well as coordination and management services related to these
services,
(b) Coordination and
management services related to activities such as sales, post-sales support,
technical support, research and development, external procurement, testing of
newly developed products, and laboratory services”
Additionally, the Ministry of
Industry and Technology is granted the authority to determine the procedures
and principles regarding the implementation of this article, subject to
obtaining the opinions of the Ministry of Treasury and Finance and the Ministry
of Trade.
Employees who directly perform
these services and are not classified as support staff are also defined as
qualified service personnel.
This provision entered into
force on June 4, 2026, the date of publication of the Law.
Amendments to the Corporate Income Tax Law (Transit Trade and Qualified Service Center Income Deduction)
- Transit Trade Income Deduction
Under Article 7 of the
aforementioned Law, the scope of the profit deduction for transit trade set
forth in the first paragraph of Article 10 of the Corporate Income Tax Law has
been expanded.
In this context,
- The profit deduction rate for entities operating in the Istanbul Financial Center with a participant certificate is increased from 50% to 100%.
- Additionally, it has been stipulated that the profit deduction rate of 100% shall apply to industrial zones established under the Industrial Zones Law No. 4737 dated January 9, 2002, provided that such zones are deemed appropriate by the President based on the level of foreign investment in the region.
- Institutions operating outside the Istanbul Financial Center and Industrial Zones are also granted a 95% profit deduction.
- To qualify for the deduction, the profit must have been transferred to Turkey by the deadline for filing the annual corporate income tax return for the fiscal year in which the profit was earned, and neither the seller nor the buyer of the goods related to the brokerage activity may be located in Turkey.
- Corporate Income Tax Deduction for Income Earned from Abroad by the Istanbul Financial Center (IFC) and the Qualified Services Center Exclusively in Connection with These Activities
For income earned from abroad exclusively in connection with their activities as qualified service centers operating under the Direct Foreign Investment Law No. 4875,
- For institutions operating as qualified service centers in the Istanbul Financial Center Zone by obtaining a participant certificate in accordance with the provisions of Law No. 7412, as well as those established in industrial zones under Law No. 4737 that are deemed appropriate by the President based on the zone’s foreign investment density, a 100% income tax reduction incentive is provided,
- A 95% income tax incentive is provided if they operate outside these zones and centers,
at the aforementioned rates.
This provision entered into
force on the date of its publication, effective for corporate income pertaining
to the tax period beginning on January 1, 2026 (or, for entities with a
designated special fiscal year, the fiscal year beginning on January 1, 2026),
and applies to tax returns required to be filed starting on July 1, 2026.
Application of a 12.5%
Corporate Income Tax Rate on Income Derived from Manufacturing and Agricultural
Activities
Pursuant to Article 8 of the
aforementioned Law, the amendment made to Article 32 of the Corporate Income
Tax Law, titled “Corporate Income Tax and Provisional Tax Rate,” , stipulates that
the corporate tax rate shall be applied at 12.5% for the profits
derived exclusively from production activities by entities holding an
industrial registry certificate and actually engaged in production activities,
as well as for the profits derived exclusively from agricultural production
activities by entities engaged in such activities.
Additionally, it is stipulated
that no further deductions may be applied under the seventh paragraph of
Article 32 of Law No. 5520 for profits benefiting from this reduced corporate
income tax rate.
This provision will
enter into force on the date of its publication and will apply to income earned
in 2027 and subsequent tax periods; for entities subject to a special fiscal
year, it will apply to income earned during the special fiscal year beginning
in the 2027 calendar year and subsequent tax periods.
Deductibility of Income
Deductions for Transit Trade, Qualified Service Centers, and Financial Services
Exports from the Minimum Corporate Tax Base
Article 9 of the
aforementioned Law establishes provisions regarding the deductibility of income
deductions for transit trade, qualified service centers, and financial services
exports from the minimum corporate tax base.
With the addition of
subparagraphs (i) and (j) to subparagraph (b) of the second paragraph of
Article 32/C of the Corporate Income Tax Law—which governs deductions allowable
from the income subject to the domestic minimum corporate income tax
calculation—the Corporate Income Tax Law , the provisions regarding the
deduction of corporate income tax reductions provided for transit trade and
qualified service center profits under subparagraphs (i) and (j) of the first
paragraph of Article 10, as well as the corporate income tax reduction provided
for entities operating in Industrial Zones and the Istanbul Financial Center,
from the corporate income serving as the basis for the calculation of the
domestic minimum corporate income tax have been established.
This provision entered into
force on the date of its publication and applies to corporate income for the
tax period beginning on January 1, 2026 (or the accounting period beginning on
January 1, 2026 for entities with a designated special accounting period),
effective for tax returns required to be filed starting July 1, 2026.
Asset Amnesty Regulation
The Asset Amnesty regulation
was established through Transitional Article 19, which was added to the
Corporate Income Tax Law by Article 10 of the aforementioned Law.
The regulation encourages the
repatriation of cash, gold, foreign currency, securities, and other capital
market instruments held abroad by individuals and legal entities, thereby
contributing to the national economy.
It also allows income and
corporate tax payers to declare assets of the same type located in Turkey but
not recorded in their legal books and records, subject to the conditions set
forth in the article.
To benefit from the provisions
of this article, a declaration must be filed by July 31, 2027, and the assets
must be brought into Turkey within two months of the declaration date.
It is stipulated that assets
reported under this provision will be placed in a special reserve account on
the balance sheet and cannot be withdrawn from the business for two years.
It is required that assets
located within Turkey be deposited with banks or financial institutions as of
the date of the declaration.
In addition, different tax
rates are determined based on the maturity dates and reporting periods of the
investment instruments for which a commitment has been made to deposit the
reported assets; in this context, banks and brokerage firms will, in their
capacity as tax agents, declare the tax—which they will collect in advance at a
rate of 5% of the value of the assets reported to them—to the tax office under
their jurisdiction via a tax return by the evening of the 15th day of the month
following the notification, and will pay the tax within the same timeframe.
If a commitment is made that the reported asset will be held for the periods specified below in term deposits, government domestic debt securities issued under Law No. 4749, lease certificates, or venture capital investment funds, the tax will be applied at the rates specified opposite each period;
5% if no commitment is made,
- 0% if a commitment is made to hold the assets for at least 5 years,
- 1% if a commitment is made to hold the assets for at least 4 years,
- 2% if a commitment is made to hold the assets for at least 3 years,
- 3% if a commitment is made to hold the assets for at least 2 years,
- 4% if a commitment is made to hold the assets for at least 1 year,
For declarations submitted
between January 1, 2027, and July 31, 2027, these rates will be applied with an
additional half-point increase.
In the event of an extension
of the declaration period, declarations submitted after July 31, 2027, will be
subject to a total increase of 1 point, including the additional half-point
increase. No stamp duty will be levied on the undertakings submitted under this
paragraph.
It is stipulated that under no
circumstances shall a tax audit or tax assessment be conducted regarding the
amounts corresponding to the reported assets, provided the conditions set forth
in the relevant provision are met; however, it is clarified that the absence of
a tax assessment under this provision does not imply that measures required
under other legislation will not be applied.
It is stated that if the
conditions are not met, the provision regarding the inability to conduct a tax
audit or assessment cannot be utilized; taxes already collected will not be
refunded or returned, and declared taxes will be collected with late payment
interest.
Additionally, the President
may extend the deadline of July 31, 2027, in periods not exceeding six months
each, up to a total of one year; The Ministry of Treasury and Finance is
authorized to determine the procedures regarding the importation, declaration,
and inclusion of assets covered by this article into business operations, the
form of such declarations and reports, the information and documents to be used
in the application of this article, and the procedures and principles governing
its implementation.
The aforementioned article
entered into force on June 4, 2026, the date of publication of the Law.
Financing and Exemption
Regulations for Techno-Initiatives
Pursuant to Article 11 of the
aforementioned Law, the following paragraphs have been added to Article 3 of
Law No. 5746 on the Support of Research, Development, and Design Activities,
dated February 28, 2008.
“(15) In conditional capital
increases to be carried out by non-publicly traded companies holding a techno-initiative
badge issued by the Ministry of Industry and Technology, based on convertible
debt agreements, the provisions of the Turkish Commercial Code No. 6102 dated
January 13, 2011, regarding conditional capital increases shall not apply. The
procedures and principles governing the conditional capital increases of
companies falling under this scope shall be determined by the Ministry of
Industry and Technology upon the opinion of the Ministry of Trade.
(16) Companies established and
operated in accordance with the definition of a digital company to be
determined by the Ministry of Industry and Technology by entrepreneurs who have
qualified as incubator entrepreneurs under Law No. 4691
are exempt from the fees and
dues defined in Article 24 of the Law No. 5174 on the Union of Chambers and
Commodity Exchanges of Turkey and Chambers and Commodity Exchanges, dated May
18, 2004, for a period of up to three years from the date of establishment.”
Accordingly, the provisions of
the Turkish Commercial Code regarding conditional capital increases will not
apply to conditional capital increases carried out by privately held companies
holding the “Techno-Initiative” badge issued by the Ministry of Industry and
Technology, based on debt instruments convertible into equity. Regulations have
been established to allow the Ministry of Industry and Technology to determine
the procedures and principles for such conditional capital increases, subject
to the opinion of the Ministry of Trade.
A regulation has been enacted
to exempt companies established and operated in accordance with the definition
of a “digital company” to be determined by the Ministry of Industry and
Technology—by entrepreneurs who have qualified as incubator entrepreneurs under
the Technology Development Zones Law—from the payment of fees and dues defined
in the relevant provision of the Union of Chambers and Commodity Exchanges of
Turkey and the Chambers and Commodity Exchanges Law .
The aforementioned provision
entered into force on June 4, 2026, the date of publication of the Law.
Expanding the Income Tax
Deduction at the Istanbul Financial Center to Include All Participants
Pursuant to Article 12 of the
aforementioned Law, the phrase “financial institutions that have obtained a
participant certificate” in the first sentence of the second paragraph of
Article 6 of the Istanbul Financial Center Law No. 7412 dated June 22, 2022,
has been replaced with “participants,” and the following sentence has been
added to the paragraph:
“The exemption set forth in
subparagraph (20) of the first paragraph of Article 23 of the Income Tax Law
No. 193 dated December 31, 1960, shall not apply to personnel of qualified
service centers benefiting from this exemption.”
Accordingly, a regulation has
been enacted to expand the income tax deduction provided to financial
institutions in the Istanbul Financial Center—which applies when employing
personnel with international experience—to cover all participants.
A provision has also been
established stating that personnel benefiting from this deduction cannot avail
themselves of the salary exemption introduced by Article 5 of this Law to the
Income Tax Law, as summarized above.
The aforementioned provision
entered into force on June 4, 2026, the date of publication of the Law.
Extension of the Incentive
Period for Institutions Engaged in Financial Activities by Obtaining a
Participant Certificate at the Istanbul Financial Center
Pursuant to Article 13 of the
aforementioned Law, the term “2031” in the first paragraph of the transitional
Article 1 of Law No. 7412 has been amended to “2047,” and the term “five” in
the second paragraph has been amended to “twenty.”
Accordingly, the period for
the corporate tax deduction applied at a rate of 100% on the profits of
institutions engaged in financial activities by obtaining a participant
certificate at the Istanbul Financial Center has been extended until 2047, and
a regulation has been enacted to extend the exemption period from financial
activity fees for the establishment and licensing of these institutions from 5
years to 20 years.
The relevant provision entered
into force on June 4, 2026, the date of the Law’s publication.
You can access the relevant
law via the following link: https://www.resmigazete.gov.tr/eskiler/2026/06/20260604-1.htm
We are pleased to provide you
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