ARTICLE
8 January 2026

Amendments Regarding FX Conversion Support For Foreign Exchange–Earning Services

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Herguner Bilgen Ucer Attorney Partnership

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Hergüner Bilgen Üçer is one of Türkiye’s largest, full-service independent corporate law firms representing major corporations and clientele, and international financial institutions and agencies. Hergüner not only provides expert legal counsel to clients, but also serves as a trusted advisor and provides premium legal advice within a commercial context.
In this context, the "Implementation Instruction on the Support of the Conversion of Companies' Foreign-Sourced Foreign Exchange into Turkish Lira" ("Implementation Instruction") was published, whereby the definition of foreign-sourced foreign exchange eligible for support was revised.
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On 8 December 2025, the Treasury and Corporate Operations General Directorate of the Central Bank of the Republic of Türkiye introduced significant changes to the FX conversion support mechanism applicable to foreign exchange–earning services. In this context, the "Implementation Instruction on the Support of the Conversion of Companies' Foreign-Sourced Foreign Exchange into Turkish Lira" ("Implementation Instruction") was published, whereby the definition of foreign-sourced foreign exchange eligible for support was revised.

Pursuant to the amendments introduced under the Implementation Instruction, in order to benefit from FX conversion support in respect of foreign exchange–earning service revenues, the all of the following conditions must be satisfied together:

i. the company must hold a valid Tax, Duty and Fee Exemption Certificate (Vergi, Resim ve Harç İstisna Belgesi – "VRHİB") issued by the Ministry of Trade of the Republic of Türkiye under the Communiqué on Tax, Duty and Fee Exemptions for Exports, Transit Trade, Sales and Deliveries Deemed as Exports, and Foreign Currency-Earning Services and Activities ("Communiqué No. 2017/4");

ii. the foreign exchange–earning service revenues must be derived from invoices issued in relation to the activities covered by the VRHİB; and

iii. the amount subject to support must not exceed the activity amount recorded under the VRHİB.

Within this scope, service revenues that are not compatible with the scope and amount specified in the VRHİB will not be eligible for FX conversion support. Submission of the VRHİB and the relevant invoices to the intermediary bank has now become mandatory to ensure that the said conditions can be applied. . Also, intermediary banks have been obliged to verify whether the foreign exchange has been generated from activities falling within the scope of the VRHİB and whether the amount of foreign exchange to be sold is consistent with the amount specified in the VRHİB.

Furthermore, intermediary banks that fail to fulfil the control obligations set out under the Implementation Instruction shall be jointly and severally liable together with the relevant companies for any losses and punitive sanctions that may arise in connection with foreign exchange conversion support payments made in violation of the Implementation Instruction.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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