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Information Note on the Draft Law Introducing Amendments to Tax Legislation

 

Information Note on the Draft Law Introducing Amendments to Tax Legislation

 

The Draft Law on Amendments to Certain Laws, submitted to the Grand National Assembly of Türkiye on 5 May 2026, proposes significant changes to Turkish tax legislation.

The draft law has not yet been enacted and may be amended during the parliamentary process. Therefore, the explanations below have been prepared based on the current version of the draft law and the updates made during the Planning and Budget Committee stage.

 

1. New Asset Repatriation Regime

The draft law proposes to allow real persons and legal entities to declare certain assets located either abroad or in Türkiye, which have not previously been recorded in statutory books, and bring them into the formal system.

The assets covered generally include cash, gold, foreign currency, securities and other capital market instruments.

According to the draft law, assets located abroad must be declared to banks or intermediary institutions by 31 July 2027 and must be brought to Türkiye or transferred to bank/intermediary institution accounts in Türkiye within 2 months following the declaration date.

A general tax rate of 5% is proposed for the declared assets. However, this rate may be reduced to 0%, depending on the taxpayer’s commitment to keep the assets in Türkiye for certain periods. If the statutory conditions are met, no tax audit or tax assessment is intended to be carried out in relation to the declared assets.

2. Reduced Corporate Income Tax Rate for Production and Agricultural Production Income

The initial version of the draft law proposed significant reductions in corporate income tax rates applicable to income derived from export activities.

Under the initial draft:

  • a 9% corporate income tax rate was proposed for income derived by manufacturers from the direct export of goods they produce, 
  • a 14% corporate income tax rate was proposed for income derived by other exporters exclusively from export activities. 

However, this provision was amended during the Planning and Budget Committee discussions. Under the current text accepted at Committee level, the 9% / 14% rate structure specifically targeting exporters has been removed. Instead, a new reduced rate regime has been introduced for production and agricultural production income.

According to the current text, the corporate income tax rate is proposed to be applied as 12.5% for:

  • income derived exclusively from production activities by companies holding an industrial registry certificate and actually engaged in production activities, 
  • income derived exclusively from agricultural production activities by companies engaged in agricultural production. 

In addition, the existing 5-point corporate income tax reduction applicable to export income will not be applied separately to income benefiting from this reduced rate.

This provision is expected to apply to income derived in 2027 and subsequent tax periods, if enacted in its current form.

Nevertheless, the provision has not yet been enacted. It may be further amended during the General Assembly discussions. Therefore, the final enacted text, effective dates and any secondary regulations should be closely monitored.

3. Qualified Service Centre Incentive

The draft law proposes to introduce a new incentive mechanism under the name of qualified service centres.

Under this regime, capital companies providing services to related companies operating in at least three different countries may benefit from the incentive, provided that at least 80% of their annual revenue is derived from related companies located abroad.

The services covered include financial advisory, strategic management, risk management, treasury and liquidity management, budgeting, financial reporting, audit, digital transformation, legal advisory, human resources, training, technical support, R&D, and coordination services.

It is proposed that 95% of the qualifying income derived from abroad by these centres will be deductible from corporate income. For qualified service centres operating in the Istanbul Financial Center, the deduction rate is proposed to be 100%.

In order to benefit from the deduction, the relevant income must be transferred to Türkiye by the deadline for filing the annual corporate income tax return.

4. Income Tax Exemption for Qualified Service Personnel

The draft law proposes an income tax exemption for a certain portion of the salaries paid to qualified personnel employed by qualified service centres.

Accordingly:

  • for personnel employed in qualified service centres, the portion of salary not exceeding 3 times the gross minimum wage may be exempt from income tax, 
  • for personnel employed in qualified service centres operating in the Istanbul Financial Center, the exemption threshold may be applied as 5 times the gross minimum wage. 

5. Transit Trade and Foreign Goods Trading Income

The draft law proposes to expand the corporate income tax advantages applicable to transit trade and foreign goods trading activities.

Accordingly, 95% of the income derived from the sale abroad of goods purchased from abroad without being brought into Türkiye, or from intermediation in foreign goods trading transactions, is proposed to be deductible from corporate income.

For participants operating in the Istanbul Financial Center, the deduction rate is proposed to be 100%.

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.

6. Istanbul Financial Center Regulations

The draft law also proposes to expand and extend certain tax advantages available under the Istanbul Financial Center regime.

In particular, the following changes are proposed:

  • extension of the 100% corporate income tax deduction applicable to financial service export income until 2047, 
  • extension of the exemption period from financial activity fees for participating financial institutions to 20 years, 
  • application of a 100% deduction for transit trade and foreign goods trading income of Istanbul Financial Center participants. 

 

7. Foreign-Sourced Income Exemption for Individuals Relocating to Türkiye

The draft law proposes an important income tax exemption for individuals who subsequently become tax residents in Türkiye.

Accordingly, individuals who did not have a domicile or tax liability in Türkiye during the last 3 calendar years before becoming resident in Türkiye may benefit from an income tax exemption for their foreign-sourced income and gains for 20 years.

In addition, for these individuals, assets transferred by inheritance during the exemption period are proposed to be subject to inheritance and gift tax at a flat rate of 1%.

8. Shares Granted to Employees of Tech Start-Up Companies

The draft law proposes to expand the income tax exemption applicable to shares granted free of charge or at a discount to employees of tech start-up companies.

In this respect, the upper limit of the exemption is proposed to be set at twice the employee’s annual gross salary, and the preservation of the tax benefit will depend on the holding period of the relevant shares.

9. Extension of Tax Debt Deferral Period and Increase in Unsecured Deferral Limit

The draft law proposes important changes to the deferral and instalment payment rules applicable to public receivables under Law No. 6183.

Accordingly:

  • the maximum deferral period is proposed to be increased from 36 months to 72 months, 
  • the amount of tax debt that may be deferred without security is proposed to be increased to TRY 1,000,000. 

This may provide an important payment flexibility for taxpayers experiencing temporary cash flow difficulties.

Conclusion

The draft law includes important proposed changes in several areas, including asset repatriation, reduced corporate income tax for production income, qualified service centres, transit trade, the Istanbul Financial Center, tech start-ups and tax debt deferrals.

In particular, the 9% / 14% rate structure for exporters, which was included in the initial draft, has been amended during the Planning and Budget Committee stage. Under the current text, a 12.5% corporate income tax rate is proposed for production and agricultural production income.

The draft law has not yet been enacted. Therefore, the final text to be adopted by the General Assembly, the effective dates and any secondary regulations should be closely monitored.

We will continue to follow the legislative process and share further updates once the developments are finalized.

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