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Recent Development
Law No. 7582 on the Amendment of Certain Laws (the “Law”) was published in the Official Gazette dated 4 June 2026. The Law introduces significant amendments in various key areas, particularly tax legislation and foreign direct investment law.
The Law constitutes a comprehensive investment and incentive package aimed at attracting foreign capital and Turkish investors who have long resided abroad to Türkiye, encouraging multinational companies to choose Türkiye as a regional operations hub, supporting the manufacturing sector, and bringing offshore assets into the economy.
1. Amendments to Law No. 6183 on the Procedure for the Collection of Public Receivables
| Amendment | What Does the Amendment Mean? |
| In the first paragraph of Article 48 of Law No. 6183 on the Procedure for the Collection of Public Receivables dated 21 July 1953, the phrase “36” has been amended as “72”, and in the second paragraph, the phrase “fifty thousand new Turkish liras” has been amended as “one million Turkish liras”. | With this amendment, the maximum instalment period for deferment, which may be applied where it is determined that the payment of the public debt would place the debtor in a very difficult position, has been increased from 36 months to 72 months. In addition, the debt threshold for deferment without collateral has been increased from TRY 50,000 to TRY 1,000,000; accordingly, public debts below this threshold may be deferred without requiring collateral. |
2. Amendments to Income Tax Law No. 193
| Amendment | What Does the Amendment Mean? |
| In the first paragraph of Article 17 of Income Tax Law No. 193 dated 31 December 1960, the phrase “amount” has been amended as “twice the amount”, and in the second paragraph, the phrases “three”, “four”, “six”, “seven” and “twelve” have been amended as “two”, “three”, “four”, “five” and “six”, respectively. | Share certificate exemption for technology ventures personnel (Article 17): The upper limit of the income tax exemption applicable to benefits provided to employees of technopreneurship companies through the granting of share certificates has been increased to twice the employee’s annual gross salary. In addition, the period required for the exemption to become permanent (i.e., for the share certificates to be disposed of without giving rise to any repayment obligation) has been reduced from 12 years to 6 years. The partial repayment thresholds have also been shortened accordingly. |
| The following subparagraph has been added to the first paragraph of Article 23 of Law No. 193: “20. The portion of the wages of qualified service personnel employed in qualified service centers defined under Additional Article 1 of the Foreign Direct Investment Law No. 4875 dated 5 June 2003 that does not exceed three times the gross minimum wage (to be applied as five times the gross minimum wage for qualified service centers operating in industrial zones established under the Industrial Zones Law No. 4737 dated 9 January 2002, which are deemed appropriate by the President based on the foreign investment intensity of the zone, and for qualified service centers operating in the Istanbul Finance Center by obtaining a participant certificate). The President is authorized to determine the three- and five-fold limits set out in this subparagraph, jointly or separately, down to one-fold, or to increase them up to two-fold.” |
Wage exemption for qualified service personnel (Article 23): An exemption mechanism has been introduced for wage income earned by personnel employed in qualified service centers and defined under the law as “qualified service personnel”. Wage income up to three times the monthly gross minimum wage will be exempt from income tax; this threshold will be increased to five times the monthly gross minimum wage for centers located in the Istanbul Finance Center and certain industrial zones. |
| The following article has been added to Law No. 193 after repeated Article 20/C: “Tax exemption for income and revenues obtained abroad: REPEATED ARTICLE 20/D — Income and revenues obtained outside Türkiye by real persons deemed to be resident in Türkiye shall be exempt from income tax for twenty years, provided that such persons had no residence and tax liability in Türkiye during the last three calendar years before they were deemed to be resident in Türkiye. The fact that real persons within the scope of the first paragraph had a tax liability in Türkiye before falling within the scope of this article due to immovable property income, movable property income or capital gains obtained in Türkiye shall not prevent them from benefiting from this exemption. No annual tax return shall be filed for income and revenues within the scope of the first paragraph, and where a tax return is filed due to other income, such income and revenues shall not be included in the tax return. Expenses and costs relating to income and revenues within the scope of the exemption shall not be taken into account in the determination of taxable income and revenues. Taxes paid in foreign countries in respect of income and revenues within the scope of this exemption may not be credited against income tax assessed in Türkiye. If it is subsequently determined that the conditions for the exemption have not been met, taxes that were not assessed shall be deemed to have been subject to tax loss. The Ministry of Treasury and Finance is authorized to determine the procedures and principles regarding the implementation of this article.” |
Exemption for income and revenues obtained abroad (Repeated Article 20/D): This article introduces an exemption regime under which real persons who newly become resident in Türkiye will not be subject to income tax in Türkiye for 20 years on income and revenues obtained outside Türkiye. To benefit from the exemption, the relevant person must not have had residence or tax liability in Türkiye during the last three calendar years before being deemed resident in Türkiye. Having previously established tax liability in Türkiye due to passive income such as rental income, interest income or capital gains before becoming resident in Türkiye will not prevent the person from benefiting from the exemption. |
3. Amendments to Foreign Direct Investment Law No. 4875
| Amendment | What Does the Amendment Mean? |
| The following additional article has been added to the Foreign Direct Investment Law No. 4875 dated 5 June 2003: “Qualified service center ADDITIONAL ARTICLE 1 — A qualified service center refers to capital companies established to provide services to an affiliated company or group of companies actively operating in at least three different countries and to carry out the activities specified in the second paragraph, deriving at least 80% of their annual revenues from affiliated companies or groups of companies abroad. These centers provide: a) Coordination and management services relating to financial advisory, strategic management consultancy, risk management, cash and liquidity management, funding and borrowing transactions, investment and capital structure planning, budgeting, financial reporting and analysis, international accounting and compliance, audit, digital transformation and technology consultancy, investment and data analysis, legal consultancy (legal consultancy relating to domestic activities or Turkish law only by obtaining such services from lawyers or law partnerships authorized to provide services under the Attorneyship Law No. 1136 dated 19 March 1969), promotion, brand management, human resources and training services; b) Coordination and management services relating to activities such as sales, after-sales support, technical support, research and development, external procurement, testing of newly developed products and laboratory services. Employees who directly perform the services within the scope of the second paragraph, excluding support personnel, are qualified service personnel. The Ministry of Industry and Technology is authorized to determine the procedures and principles regarding the implementation of this article by obtaining the opinions of the Ministry of Treasury and Finance and the Ministry of Trade.” |
This article defines the status of “qualified service center” for capital companies established in Türkiye to provide services to affiliated companies or groups of companies operating in at least three different countries and deriving at least 80% of their annual revenues from affiliated companies abroad. The services that may be provided by centers with this status are listed under two categories: first, management and support services such as financial advisory, risk management, legal consultancy, human resources and digital transformation; and second, coordination services relating to operational activities such as sales, research and development, technical support and procurement. Employees who directly perform these services, excluding support personnel, are considered “qualified service personnel”. Centers falling within this definition may benefit from the relevant incentive regime in terms of the corporate income tax deduction and personnel wage exemption provided under the Law, provided that the other conditions are also met. In terms of legal consultancy services relating to Turkish law or activities in Türkiye, the Law requires such services to be obtained from lawyers or law partnerships authorized to provide services under Attorneyship Law No. 1136. |
4. Amendments to Corporate Income Tax Law No. 5520
| Amendment | What Does the Amendment Mean? |
| The following provisional article has been added to Law No. 5520: “PROVISIONAL ARTICLE 19 — (1) In order to increase voluntary tax compliance, real persons or legal entities may notify banks or intermediary institutions, until 31 July 2027, of money, gold, foreign currency, securities and other capital market instruments located abroad. (2) Assets notified pursuant to the first paragraph must be transferred, within two months from the date of notification, to accounts opened in the name of the relevant persons at banks or intermediary institutions in Türkiye, or, where physically brought from abroad, must be deposited into such accounts. The bringing of physically imported assets into Türkiye shall be documented with documents relating to the declaration to be made to the Customs Administration. The Customs Administration shall notify the Revenue Administration of the declarations received within this scope by the end of the month following the month in which they are received. (3) Money, gold, foreign currency, securities and other capital market instruments owned by income or corporate income taxpayers and located in Türkiye but not included in statutory books shall be notified to banks or intermediary institutions until 31 July 2027. It is mandatory that the notified assets be documented by depositing them with banks or intermediary institutions as of the notification date. (4) Assets notified within the scope of the first and third paragraphs shall be recorded in statutory books as of the notification date by taxpayers keeping books pursuant to Law No. 213. Taxpayers keeping books on a balance sheet basis shall open a special fund account under liabilities for the assets recorded in their statutory books pursuant to this article. This fund account may not be withdrawn from the business for two years from the notification date and may not be used for any purpose other than capital increase; however, it shall not be taxed in the event of liquidation of the business. Taxpayers keeping self-employment earnings books and operating account books shall separately show such assets in their books. These assets shall not be taken into account in determining the period earnings and, provided that two years have passed from the notification date, may be withdrawn from the business without being taken into account in determining taxable income and, for corporations, distributable earnings. (5) Persons who do not have income or corporate income tax liability shall benefit from the provisions of this article without being subject to the conditions set out in the fourth paragraph, provided that they bring the assets they notify into Türkiye within the period specified in the second paragraph and document their domestic assets by depositing them with banks or intermediary institutions as of the notification date. (6) Banks and intermediary institutions shall collect in advance from the notifying party a tax at the rate of 5% over the value of the assets notified to them, declare such tax as tax responsible to the tax office to which they are affiliated by the evening of the fifteenth day of the month following the notification, and pay it within the same period. However, if it is undertaken that the notified assets will be held in time deposit accounts, government domestic debt securities issued under Law No. 4749, lease certificates or venture capital investment funds, the tax rate shall be applied as 0% if they are undertaken to be held for at least five years, 1% for at least four years, 2% for at least three years, 3% for at least two years, and 4% for at least one year. For notifications to be made from 1 January 2027 until 31 July 2027, inclusive, these rates shall be increased by half a point. If the date of 31 July 2027 is extended by authorization, notifications made after such date shall be subject to an additional half-point increase, resulting in a total increase of one point. No stamp tax shall be collected on undertakings to be issued within the scope of this paragraph. (7) The tax paid within the scope of this article may not be recorded as an expense under any circumstances and may not be offset against any other tax. Losses arising from the disposal of the assets subject to notification shall not be accepted as expenses or deductions for income or corporate income tax purposes. (8) No tax inspection or tax assessment shall be conducted in any manner in relation to amounts corresponding to the assets notified. However, measures required to be taken under other legislation shall not be affected by this regulation. If, as a result of tax inspections initiated for other reasons or decisions of tax assessment commissions, it is determined that the tax base difference arises from the assets notified within the scope of this article and the amount of notified assets is equal to or greater than the tax base difference, no assessment shall be made in relation to the tax base difference. If, despite the determination that the tax base difference arises from the notified assets, such difference exceeds the amount of such assets, tax assessment shall be made only on the difference. If, as a result of tax inspections or decisions of tax assessment commissions, a tax base difference is identified for reasons other than the assets subject to notification, assessments shall be made without deducting the amounts notified within the scope of this article from the tax base difference identified. (9) The provision of the eighth paragraph shall not apply if the assets notified pursuant to the first paragraph are not brought into Türkiye within two months from the date of notification or are not transferred to an account to be opened at banks or intermediary institutions in Türkiye, or if assets notified pursuant to the third paragraph are not deposited with banks or intermediary institutions within the period specified in the same paragraph, or if the taxes assessed in relation to the notified amounts are not paid within the prescribed period, the undertakings are not complied with, or the other conditions set out in this article are not fulfilled. In addition, taxes that were not assessed on time shall be collected together with default interest, without applying a tax loss penalty. The provision of the eighth paragraph shall also not apply to assessments to be made as a result of tax inspections or decisions of tax assessment commissions in respect of notifications made under this article after the date on which a tax inspection was initiated or referral was made to a tax assessment commission. Failure to pay the accrued tax on its due date shall not prevent the tracking and collection of the principal tax together with late payment surcharge pursuant to Law No. 6183. Taxes collected shall not be rejected or refunded. (10) No correction may be made to notifications after the notification period has expired. (11) The President is authorized to extend the date of 31 July 2027 for periods not exceeding six months each time, up to one year from the expiry date; and the Ministry of Treasury and Finance is authorized to determine the matters relating to bringing the assets within the scope of this article into Türkiye, their notification and inclusion in the business, the forms serving as basis for notification and declaration, the information and documents to be used in the implementation of the article, and the procedures and principles regarding implementation.” |
Asset repatriation regime (Provisional Article 19): This regulation introduces an amnesty mechanism allowing money, gold, foreign currency, securities and other capital market instruments located abroad or located in Türkiye but not reflected in statutory books to be notified to banks or intermediary institutions until 31 July 2027. A tax of 5% is generally collected on the notified assets; however, if it is undertaken that the assets will be held in certain instruments such as time deposit accounts, government domestic debt securities, lease certificates or venture capital investment funds, this rate may be reduced to 0% depending on the undertaking period. In addition, no tax inspection or assessment may be conducted in relation to amounts corresponding to the notified assets; the notification closes past-period tax risks in proportion to the declared amount. |
| Subparagraph (i) of the first paragraph of Article 10 of Corporate Income Tax Law No. 5520 dated 13 June 2006 has been amended as follows and the following subparagraph has been added to the paragraph: “i) 95% of the income derived from the sale abroad of goods purchased from abroad without being brought into Türkiye or from intermediating the purchase and sale of goods occurring abroad (this rate shall be applied as 100% for institutions operating in industrial zones established under Industrial Zones Law No. 4737 dated 9 January 2002, which are deemed appropriate by the President based on the foreign investment intensity of the zone, and for institutions operating in the Istanbul Finance Center Region by obtaining a participant certificate pursuant to the provisions of Istanbul Finance Center Law No. 7412 dated 22 June 2022). In order to benefit from this deduction, the income must be transferred to Türkiye by the deadline for filing the annual corporate income tax return for the accounting period in which the income is derived, and the seller and buyer of the goods relating to the intermediary activity must not be located in Türkiye. The President is authorized to reduce the rates set out in this subparagraph to zero or to increase them up to 100%.” “j) 95% of the income obtained from abroad by institutions operating as qualified service centers within the scope of Foreign Direct Investment Law No. 4875, exclusively within the scope of such activities (this rate shall be applied as 100% for institutions operating as qualified service centers in industrial zones established under Law No. 4737, which are deemed appropriate by the President based on the foreign investment intensity of the zone, and in the Istanbul Finance Center Region by obtaining a participant certificate pursuant to the provisions of Law No. 7412). This deduction shall apply for twenty accounting periods starting from the accounting period in which the qualified service center commenced its activities, provided that the income is transferred to Türkiye by the deadline for filing the annual corporate income tax return for the accounting period in which the income is derived. The President is authorized to reduce the rates set out in this subparagraph down to 50% or to increase them up to 100%.” |
Transit trade income deduction (Article 10/i): This subparagraph allows 95% of the income derived from the sale abroad of goods purchased from abroad without being brought into Türkiye, or from intermediating the purchase and sale of goods abroad, to be deducted from corporate income. This rate is applied as 100% for institutions operating in certain industrial zones and in the Istanbul Finance Center. To apply the deduction, the income must be transferred to Türkiye by the deadline for filing the annual corporate income tax return, and the buyer and seller of the goods subject to the intermediary activity must not be located in Türkiye. Qualified service center income deduction (Article 10/j): This subparagraph allows 95% of the income obtained from abroad by institutions operating as qualified service centers under the Foreign Direct Investment Law, exclusively within the scope of such activities, to be deducted from corporate income. This rate is applied as 100% for qualified service centers operating in certain industrial zones and in the Istanbul Finance Center. The deduction applies for twenty accounting periods starting from the accounting period in which the center commences its activities, provided that the income is transferred to Türkiye by the deadline for filing the annual corporate income tax return. |
| The eighth paragraph of Article 32 of Law No. 5520 has been amended as follows: “(8) The corporate income tax rate shall apply as 12.5% to the income derived exclusively from manufacturing activities by institutions holding an industrial registry certificate and actually engaged in manufacturing activities, and to the income derived exclusively from such production activities by institutions engaged in agricultural production activities. No further reduction shall be applied under the seventh paragraph for income benefiting from the reduced rate within the scope of this paragraph.” |
Reduced corporate income tax rate for manufacturing and agricultural production income (Article 32): This article provides that income derived exclusively from manufacturing activities by institutions holding an industrial registry certificate and actually engaged in manufacturing activities will be subject to a 12.5% corporate income tax rate instead of the standard 25% corporate income tax rate. The same rate will also apply to income derived exclusively from agricultural production activities by institutions engaged in such activities. Income benefiting from the 12.5% rate under this paragraph will not be subject to an additional reduction under Article 32/7 of the Corporate Income Tax Law. |
5. Amendments to Law No. 5746 on the Support of Research, Development and Design Activities
| Amendment | What Does the Amendment Mean? |
| The following paragraphs have been added to Article 3 of Law No. 5746 on the Support of Research, Development and Design Activities dated 28 February 2008: “(15) The provisions of the Turkish Commercial Code No. 6102 dated 13 January 2011 concerning conditional capital increases shall not apply to conditional capital increases to be carried out by non-public companies holding a technopreneurship badge issued by the Ministry of Industry and Technology based on convertible debt agreements. The procedures and principles regarding conditional capital increases by companies within this scope shall be determined by the Ministry of Industry and Technology upon obtaining the opinion of the Ministry of Trade. (16) Companies incorporated and operated in accordance with the digital company definition to be determined by the Ministry of Industry and Technology by entrepreneurs who have qualified to become incubation entrepreneurs under Law No. 4691 shall be exempt from the fees and dues defined under Article 24 of the Union of Chambers and Commodity Exchanges of Türkiye and Chambers and Commodity Exchanges Law No. 5174 dated 18 May 2004 for up to three years from their incorporation date.” |
This article introduces two separate facilitations for technopreneurship companies through two new paragraphs added to R&D Law No. 5746. The provisions of the Turkish Commercial Code concerning conditional capital increases will not apply to conditional capital increases based on convertible debt agreements, instruments commonly known in practice as SAFEs and convertible notes, by non-public companies holding a technopreneurship badge issued by the Ministry of Industry and Technology. The procedures and principles governing such transactions will be determined by the Ministry of Industry and Technology upon obtaining the opinion of the Ministry of Trade. In addition, digital companies incorporated and operated by entrepreneurs admitted to technopark incubation programs in accordance with the definition to be determined by the Ministry of Industry and Technology will be exempt from TOBB membership fees and dues for three years from their incorporation date. |
6. Amendments to Inheritance and Gift Tax Law No. 7338
| Amendment | What Does the Amendment Mean? |
| The following paragraph has been added after the second paragraph of Article 16 of Inheritance and Gift Tax Law No. 7338 dated 8 June 1959: “For persons benefiting from the income tax exemption under repeated Article 20/D of Income Tax Law No. 193 dated 31 December 1960, the tax rate shall apply as 1% in respect of transfers of property through inheritance occurring within the period prescribed for such exemption.” |
A fixed tax rate of 1%, significantly below the standard tariff, will apply to inheritance transfers involving persons benefiting from the exemption for income and revenues obtained abroad. This regulation supports the 20-year income tax exemption under repeated Article 20/D of the Income Tax Law with a complementary tax advantage in respect of transfers by inheritance. |
7. Amendments to Istanbul Finance Center Law No. 7412
| Amendment | What Does the Amendment Mean? |
| In the first sentence of the second paragraph of Article 6 of Istanbul Finance Center Law No. 7412 dated 22 June 2022, the phrase “financial institutions holding a participant certificate” has been amended as “participants”, and the following sentence has been added to the paragraph: “The exemption set out in subparagraph (20) of the first paragraph of Article 23 of Income Tax Law No. 193 dated 31 December 1960 shall not apply to the personnel of qualified service centers who benefit from this exemption.” |
This amendment contains two elements. First, the scope of the personnel income tax exemption under Article 6/2 of the Istanbul Finance Center Law has been expanded. Previously, the exemption applied only to personnel of “financial institutions holding a participant certificate”; with the amendment, it now applies to all “participants”, and therefore to qualified service centers operating in the Istanbul Finance Center. In addition, it has been regulated that the wage exemption under Article 23/1-(20) of the Income Tax Law will not also apply to the personnel of qualified service centers who benefit from this exemption under the Istanbul Finance Center Law. This prevents the application of a double exemption for the same wage income. |
| In the first paragraph of provisional Article 1 of Law No. 7412, the phrase “2031” has been amended as “2047”, and in the second paragraph, the phrase “five” has been amended as “twenty”. | The duration of the corporate income tax incentive granted to participating financial institutions operating in the Istanbul Finance Center has been extended until 2047, thereby providing predictability for their long-term investment and tax planning. The duration of the fee exemption under provisional Article 1 of the Istanbul Finance Center Law has also been increased from 5 years to 20 years. |
Conclusion
The amendments introduced by the Law have significant tax and structural implications for foreign investors investing or planning to invest in Türkiye, Turkish startups, multinational companies, and real persons considering relocation to Türkiye from abroad. The Law provides different effective dates for different provisions. Accordingly, while certain provisions of the Law entered into force on the date of publication, the exemption for income and revenues obtained abroad will apply to persons deemed resident in Türkiye as of 1 January 2026; the transit trade and qualified service center income deductions will apply to corporate income relating to taxation periods starting from 1 January 2026 and to tax returns required to be filed as of 1 July 2026; and the 12.5% corporate income tax rate applicable to manufacturing and agricultural production income will apply to income obtained in 2027 and subsequent taxation periods.
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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