| TAX CIRCULAR: 2026-81 | DATE: 04.06.2026 |
The Law covers a new asset-repatriation scheme, the recalibration of deferral periods for public receivables, a reduced corporate income tax rate on manufacturing and agricultural profits, corporate tax reliefs for transit-trade and qualified-service-center income, an income tax exemption for foreign-source earnings, a wage exemption for qualified personnel, facilitations for tech start-ups, and an extension of the Istanbul Finance Center (IFC) incentives. The provisions are summarized below together with their effective dates.
1. Extension of the Deferral Period for Public Receivables
Article 1 amends Article 48 of Law No. 6183, raising the maximum deferral period from 36 to 72 months and increasing the collateral-free deferral threshold from TRY 50,000 to TRY 1,000,000.
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Effective: 4 June 2026.
2. Reduced Rate under Inheritance and Transfer Tax
Article 2 introduces repeated Article 20/D of the Income Tax Law (ITL): for persons benefiting from the foreign-income exemption, inheritance transfers occurring within the exemption period are taxed at 1%.
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Effective: 4 June 2026.
3. Equity Incentive for Tech Start-up Employees
Article 3 amends Article 17 of the ITL. The amount taken into account for the income tax exemption on shares granted by tech start-ups to employees is set at twice the employee’s gross annual salary; the collection periods for deferred taxes are restructured according to holding periods.
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Effective: 4 June 2026.
4. Income Tax Exemption for Foreign-Source Earnings
Under repeated Article 20/D of the ITL (Article 4), earnings and revenues derived abroad by individuals who were not resident in Türkiye in the preceding three calendar years are exempt from income tax for 20 years. No return is filed for such income, related expenses are non-deductible, and foreign taxes are non-creditable.
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Effective: 4 June 2026, applicable to persons deemed resident from 1/1/2026.
5. Qualified Service Center (QSC) Incentives
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5.1 Wage Exemption (Art. 5-ITL Art. 23): The portion of a qualified employee’s wage not exceeding three times the gross minimum wage is exempt from income tax. In industrial zones approved by the President and within the IFC, the threshold is five times the gross minimum wage. Effective: 4 June 2026.
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5.2 Corporate Tax Reduction (Art. 7 – Law No. 4875): 95% of income derived from abroad exclusively from QSC activities may be deducted from the corporate tax base; the rate is 100% for eligible industrial zones and IFC participants. The deduction applies for twenty accounting periods from commencement, provided the income is transferred to Türkiye by the corporate tax return deadline. Effective: 4 June 2026, applicable to returns due from 1/7/2026 for periods beginning 1/1/2026.
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5.3 Definition (Art. 6 – Law No. 4875): A “qualified service center” is a company operating in at least three countries and deriving at least 80% of its revenue from abroad. Effective: 4 June 2026.
6. Reduction for Transit Trade and Service Export Income
Article 7 amends Article 10 of the Corporate Tax Law (CTL): 95% of income from selling abroad-without bringing into Türkiye-goods purchased abroad, or from intermediating such transactions, may be deducted from the corporate tax base; 100% for eligible industrial zones and IFC participants.
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Effective: 4 June 2026, applicable to returns due from 1/7/2026 for periods beginning 1/1/2026.
7. 12.5% Corporate Tax on Manufacturing and Agricultural Profits
Article 8 amends Article 32 of the CTL. Companies holding an industrial registry certificate and actually engaged in manufacturing, as well as companies engaged in agricultural production, are taxed at 12.5% on profits derived exclusively from those activities. No additional reduction under Article 32/7 of Law No. 5520 may be applied to such profits.
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Effective: 4 June 2026, applicable to profits of 2027 and subsequent periods.
8. Minimum Corporate Tax Base
Article 9 amends Article 32/C of the CTL, allowing the transit-trade, QSC, and IFC reductions to be deducted from the domestic minimum corporate tax base.
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Effective: 4 June 2026, applicable to returns due from 1/7/2026 for periods beginning 1/1/2026.
9. Asset Repatriation Scheme (Art. 10 – CTL Provisional Art. 19)
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9.1 Foreign assets: Cash, gold, foreign currency, and capital-market instruments may be reported to a bank/intermediary by 31/7/2027 and must be transferred to/brought into Türkiye within two months (physical imports evidenced by customs declaration).
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9.2 Domestic assets: Assets not recorded in the books may be reported by 31/7/2027 and evidenced by deposit with a bank/intermediary.
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9.3 Bookkeeping and fund account: Balance-sheet taxpayers open a special fund account on the liabilities side; the fund may not be withdrawn for two years, may be used only for capital increase, and is excluded from period income.
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9.4 Non-taxpayers: May benefit-without the fund-account requirement-provided assets are brought in/deposited within two months.
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9.5 Tax rate: Generally 5%. With a commitment to hold the assets in time deposits, government debt securities, lease certificates, or venture capital funds: 0% for five years, 1% for four, 2% for three, 3% for two, 4% for one year. A 0.5-point surcharge applies to declarations made from 1/1/2027.
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9.6 Inspection/assessment protection: Where conditions are met, no tax inspection or assessment is carried out.
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9.7 Breach: Failure to comply forfeits the protection; corrections are not permitted after the reporting period.
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9.8 Authority: The President may extend the period; the Ministry of Treasury and Finance sets the procedures.
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Effective: 4 June 2026.
10. Financing and Exemption Facilities for Tech Start-ups
Article 11 adds provisions to Article 3 of Law No. 5746, exempting convertible-debt arrangements of badge-holding tech start-ups from certain provisions of the Turkish Commercial Code and granting digital companies an exemption from chamber dues.
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Effective: 4 June 2026.
11. Broadening of IFC Incentives
Article 12 amends Article 6 of Law No. 7412, extending the income tax reduction tied to the employment of personnel with international experience to all participants. The wage exemption under ITL Art. 23(20) does not additionally apply to qualified personnel benefiting from this relief.
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Effective: 4 June 2026.
12. Extension of the IFC Incentive Period
Article 13 amends Provisional Article 1 of Law No. 7412, extending the tax advantage on financial-activity income until 2047 and setting the fee exemption period at 20 years.
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Effective: 4 June 2026.
