New Tax Measures for Investors and High-Net-Worth Individuals

The Law No. 7582 on “Amendments to Certain Laws”(in Turkish “Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun” hereinafter referred to as the “Law”) has been adopted on 21 May 2026 and was published at the Turkish Official Gazette under number 33270 on 4 June 2026.

The Law introduces various tax regulations, primarily concerning the inclusion of assets into the economy, extension of deferment periods for public receivables, reduced corporate tax rates for production and agricultural activity income, corporate tax reductions for transit trade and qualified service center earnings, income tax exemptions for foreign income and revenues, wage exemptions for qualified service personnel, certain facilitations for technostartups, and the extension of incentives for the Istanbul Financial Center.

1. Tax Changes for Individuals

The amendments concerning individuals are briefly summarized below.

1.1. Income Tax Exemption Introduced for Foreign Income

With Article 4 of this Law, under repeated Article 20/D added to the Income Tax Law, income and revenues earned outside Türkiye by real persons not resident in Türkiye during the last three calendar years shall be exempted from income tax for 20 years. Within this scope, no tax return shall be filed for such income, expenses and costs shall not be deducted, and taxes paid abroad shall not be credited.

1.2. Reduced Rate in Inheritance and Transfer Tax

With Article 2 of this Law, inheritance transfers subject to inheritance and transfer tax, occurring within the 20 year above mentioned period during which the exemption under repeated Article 20/D of the Income Tax Law is utilized by those whose income and revenues obtained outside Türkiye are exempted from income tax, shall be taxed at a rate of 1%.

1.3. Share Incentive Provided to Technostartup Employees

With Article 3 of this Law, through the amendment made to Article 17 of the Income Tax Law titled “Wage exemption for benefits provided through granting shares to employees”, the amount taken into account for income tax exemption regarding shares granted to employees by technostartup companies is determined as twice the employee’s annual gross wage amount for the relevant year.

1.4. Wage Exemption for Qualified Service employees

With Article 5 of this Law, through the subparagraph added to Article 23 of the Income Tax Law titled “On Wages”, the portion of wages of qualified service staff employed in Qualified Service Centers not exceeding three times the gross minimum wage is exempted from income tax. This amount shall be applied as five times the gross minimum wage for Qualified Service Centers operating in industrial zones deemed appropriate by the President and in the Istanbul Financial Center.

With Article 6 of this Law, under the regulation added to Law No. 4875, the term “qualified service center” is defined as encompassing the companies operating in at least three countries and earning at least 80% of their income abroad.

 

2. Changes Regarding Corporations

The amendments concerning corporations are briefly summarized below.

2.1. Application of 12.5% Corporate Tax Rate on Income Derived from Production and Agricultural Activities

With Article 8 of this Law, through the amendment made to Article 32 of the Corporate Tax Law titled “corporate tax and provisional tax rate”, the corporate tax rate shall be applied at 12.5% for profits earned exclusively from production activities by corporations holding an industrial registration certificate and actually engaged in production activities, as well as for profits earned exclusively from agricultural production activities by corporations engaged in such activities. The initial plan to apply corporate tax at 9% for manufacturing exporters and 14% for other exporters has been abandoned. No additional deduction shall be applied for profits benefiting from the reduced corporate tax rate within this scope.

2.2. Deduction for Transit Trade and Service Export Earnings

With Article 7 of this Law, within the scope of the amendment made to Article 10 of the Corporate Tax Law titled “Other deductions”, 95% of the profits earned from the sale abroad of goods purchased abroad without being brought into Türkiye, or from intermediary activities related to the purchase and sale of goods abroad, shall be deducted from the corporate tax base.

In addition, 95% of the profits earned abroad exclusively within the scope of the activities of the Qualified Service Centers operating under the Foreign Direct Investments Law No. 4875 shall be deducted from the corporate tax base.
In order to benefit from the deduction regarding the profits obtained from transit trade and foreign intermediary activities, the profit must be transferred to Türkiye by the deadline for filing the corporate tax return for the relevant accounting period, and the seller and buyer of the goods involved in the intermediary activity must not be located in Türkiye.

The regulation also grants the President of the Republic the authority to alter the relevant deduction rates within certain limits.

2.3. 100% Deduction on Transit Trade and Qualified Service Center Earnings in Industrial Zones

Within the scope of the amendment made to Article 10 of the Corporate Tax Law No. 5520, pursuant to Article 7 of the Law, a 100% profit deduction incentive is provided for profits earned from:

a) Transit Trade Activities by corporations operating in Industrial Zones to be designated by the President of the Republic;

b) activities of corporations operating as Qualified Service Centers in Industrial Zones designated by the President of the Republic; and,

c) from activities of corporations operating in the Istanbul Financial Center Region by obtaining a participant certificate to operate in the premises of the Istanbul Financial Center.

For Qualified Service Centers, the deduction application shall be implemented for twenty accounting periods starting from the accounting period in which the center commenced operations, provided that the profit is transferred to Türkiye by the deadline for filing the annual corporate tax return.

2.4. Regulation Regarding the Minimum Corporate Tax Base

With Article 9 of this Law, through the amendment made to Article 32/C of the Corporate Tax Law titled “Domestic minimum corporate tax”, it becomes possible to deduct profit reductions provided within the scope of transit trade, Qualified Service Centers, and the Istanbul Financial Center from the minimum corporate tax base provided not to fall below the minimum rate of 10%.

2.5. Financing and Exemption Regulations for Technostartups

With Article 11 of this Law, through the paragraphs added to Article 3 of Law No. 5746 on Supporting Research, Development and Design Activities titled “Deduction, exemption, support and incentive elements”, exceptions are introduced to certain provisions of the Turkish Commercial Code for transactions to be carried out by companies holding a technostartup badge within the scope of convertible debt agreements. In addition, digital companies are granted exemption from chamber dues during their establishment and operation periods.

2.6. Expansion of the Scope of Istanbul Financial Center Incentives

With Article 12 of this Law, through the amendment made to Article 6 of the Istanbul Financial Center Law No. 7412 titled “Exemptions and reductions regarding taxes and other financial obligations”, the income tax reduction applied in cases where personnel with foreign experience are employed, which is provided to financial institutions in the Istanbul Financial Center, has been expanded to cover all participants (operating in the premises of the center).
In addition, the wage exemption included in subparagraph (20) of paragraph one of Article 23 of the Income Tax Law shall not additionally apply to qualified service center personnel benefiting from this exemption within the scope of the Istanbul Financial Center.

With Article 13 of this Law, through the amendment made to temporary Article 1 of the Istanbul Financial Center Law No. 7412, the duration of the tax advantage provided for financial activity earnings in the Istanbul Financial Center is extended until 2047, and the exemption period for the fees is determined as 20 years.

3. Tax Amnesty and Other Rules for Both Individuals and Corporates

The tax amnesty is composed of the following rules:

3.1. Regulation Regarding the Inclusion of Assets into the Economy

With Article 10 of this Law, through temporary Article 19 added to the Corporate Tax Law, a tax amnesty is foreseen concerning the bringing into Türkiye of assets held abroad by real and legal persons as well as for the declaration of assets existing in Türkiye but not recorded in official books, provided to make the declaration until 31 July 2027 and to bring the assets in Türkiye or to deposit these assets with banks or intermediary institutions within two months from the declaration date. In such case, no tax inspection shall be conducted.

3.2. Venture Capital Investment Funds Included Within the Scope of the Asset Peace Regulation

Pursuant to Article 10 of the Law, venture capital investment funds have been also included within the scope of the reduced tax application encouraging assets reported to banks and intermediary institutions to be retained in Türkiye for certain periods. In addition, it was regulated that no stamp tax would be imposed on undertakings regarding the retention of reported assets.

3.3. Extension of Deferment Period for Public Receivables

With Article 1 of this Law, within the scope of the amendment made to Article 48 of Law No. 6183, the deferment period is extended from 36 months to 72 months, and the unsecured deferment amount is increased from TRY 50,000 to TRY 1,000,000. The previous amount was, by Presidential Decree, TRY 250,000.-.

4. Entry into Force

Pursuant to Article 14 of this Law:

a) Article 4 shall enter into force on the date of its publication (4 June 2026), to be applied to those deemed to have settled in Türkiye as of 1 January 2026,

b) Articles 7 and 9 shall enter into force on the date of publication (4 June 2026), to apply starting with the declarations required to be submitted as of 1 July 2026 and to corporate earnings pertaining to the taxation period beginning as of 1 January 2026 (for corporations assigned a special accounting period, the accounting period beginning as of 1 January 2026)

c) Article 8 shall enter into force on the date of publication, to apply to earnings obtained in the 2027 year and subsequent taxation periods, and for corporations subject to a special accounting period, to earnings obtained in the special accounting period beginning in the 2027 calendar year and subsequent taxation periods, and,

d) The other articles shall enter into force on the date of publication.

Pursuant to Article 15, the provisions of this Law shall be implemented by the President of the Republic.

 

More information

If you would like to discuss this matter with the attorneys at Cailliau & Colakel, please do not hesitate to contact the authors Didier Cailliau (d.cailliau@cailliau-colakel.av.tr) and Erhan Colakel (e.colakel@cailliau-colakel.av.tr).

For more information on our services, visit www.cailliau-colakel.av.tr.

Disclaimer

This article is based on publicly available information and is for informational purposes only. It is not intended to provide legal advice or an exhaustive analysis of the issues it mentions.

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