- within Cannabis & Hemp, Technology and Environment topic(s)
Law No. 7582 on Amendments to Certain Laws (“Law No. 7582, the Law”), which had been the subject of extensive public discussion for some time, was published in the Official Gazette dated 4 June 2026 and numbered 33270 and entered into force on the same date. Law No. 7582 introduces significant amendments to Turkish tax and investment legislation with the aim of supporting Türkiye’s adaptation to current economic developments, contributing to the objectives of the Medium-Term Programme and broader economic policies, enhancing international competitiveness, promoting economic growth and improving the balance of foreign trade.
When considered as a whole, the Law reflects a broader economic policy aimed at positioning Türkiye as a more attractive hub for international capital, investment and highly qualified talent. In this regard, the Law seeks to encourage foreign capital inflows, strengthen service exports, support manufacturing and export-oriented activities, promote high value-added investments and foster the development of Türkiye’s technology and entrepreneurship ecosystem.
Accordingly, the Law:
- introduces a new Qualified Service Centre (“QSC”) model designed to enable multinational groups to provide intragroup management, finance, technology, human resources and similar services from Türkiye,
- grants significant tax incentives for income derived abroad by QSCs and for salaries paid to qualified personnel employed by such centres;
- introduces tax incentives for income derived from offshore trading activities and intermediary services relating to international trade transactions;
- extends the duration of tax incentives available within the Istanbul Finance Centre (“IFC”) framework with a view to strengthening its international competitiveness;
- introduces a long-term income tax exemption for foreign-source income earned by individuals who become tax resident in Türkiye, thereby encouraging foreign capital and foreign currency inflows;
- provides for a reduced corporate income tax rate in respect of income derived from manufacturing and agricultural production activities; and
- introduces a new asset repatriation regime aimed at encouraging voluntary tax compliance and bringing unregistered assets into the formal economy.
In this respect, the Law goes beyond introducing merely technical amendments to tax legislation and constitutes a comprehensive package of incentives and economic measures designed to support Türkiye’s strategic objective of becoming a regional hub for investment, finance, technology and high value-added services. The principal incentives and advantages introduced by the Law are summarised below.
Introduction of a 20-Year Income Tax Exemption for Certain Individuals Becoming Resident in Türkiye (a Non-Dom Regulation)
Pursuant to Repeated Article 20/D added to the Income Tax Law, income and earnings derived outside Türkiye by individuals deemed to be resident in Türkiye shall be exempt from income tax for a period of twenty years, provided that such individuals have neither maintained a domicile nor been subject to tax residency in Türkiye during the three calendar years preceding the year in which they become resident in Türkiye (excluding tax liability arising solely from Turkish-source real estate income, movable capital income or capital gains). Furthermore, pursuant to the amendment introduced to the Inheritance and Gift Tax Law, transfers of assets by inheritance occurring during the exemption period will be subject to inheritance tax at a rate of 1%.
The Law further provides that such income will not be included in an annual income tax return and that expenses and costs relating to exempt income may not be taken into account in determining taxable income.
The relevant provision entered into force on 4 June 2026 and applies to individuals deemed resident in Türkiye as of 1 January 2026.
Introduction of a New Legal and Tax Framework for Qualified Service Centres
Law No. 7582 introduces the concept of a Qualified Service Centre into Law No. 4875 on Foreign Direct Investment. A QSC is defined as a capital company established to provide services to related companies or a corporate group actively operating in at least three different countries and deriving at least 80% of its annual revenues from affiliated companies or group entities located abroad.
The activities that may be carried out by QSCs are grouped under two categories:
- intragroup support services, including finance, management, risk and treasury management, accounting and compliance, audit, technology and digital transformation, data analytics, legal services, human resources, training and brand management, together with coordination and management services relating to such activities; and
- coordination and management services relating to sales, after-sales services, technical support, research and development, procurement and product development activities.
Pursuant to Article 10/j added to the Corporate Income Tax Law, 95% of the income derived abroad by QSCs from the activities listed above may be deducted from the corporate income tax base. This deduction will be available for twenty fiscal periods commencing from the fiscal period in which the QSC begins operations, provided that the relevant income is transferred to Türkiye by the deadline for filing the corporate income tax return for the relevant fiscal year.
In addition, the deduction applicable to the qualified services listed under item (a) above may also be taken into account in the calculation of the domestic minimum corporate income tax base.
Employees directly engaged in these activities are classified as Qualified Service Personnel. Pursuant to the amendments made to the Income Tax Law, the portion of salary income earned by Qualified Service Personnel not exceeding three times the gross minimum wage will be exempt from income tax.
Corporate Income Tax Deduction for Transit Trade and Intermediary Services Relating to Offshore Trading Activities
Pursuant to the amendment made to Article 10 of the Corporate Income Tax Law, 95% of income derived from the sale of goods purchased abroad without being brought into Türkiye, or from intermediary services relating to the purchase and sale of goods abroad, may be deducted from the corporate income tax base, provided that:
- the relevant income is transferred to Türkiye by the deadline for filing the corporate income tax return for the relevant fiscal year; and
- both the seller and the purchaser of the goods subject to the intermediary activity are located outside Türkiye.
The relevant provision entered into force on 4 June 2026 and applies to corporate income derived in taxation periods commencing on or after 1 January 2026, for returns to be filed as of 1 July 2026.
Amendments Relating to the Istanbul Finance Centre
Law No. 7582 strengthens the existing incentive framework available to participants operating within the Istanbul Finance Centre (“IFC”) and extends the duration of certain incentives.
Under the new rules, the 95% corporate income tax deduction available for income derived abroad by QSC’s and for transit trade income will apply at a rate of 100% for entities operating in the IFC with a participant certificate.
Similarly, the income tax exemption available to Qualified Service Personnel employed by Qualified Service Centres has been enhanced for IFC participants. Accordingly, the salary exemption threshold, which is generally limited to three times the gross minimum wage, will apply as five times the gross minimum wage for Qualified Service Personnel employed by QSCs operating within the IFC.
The Law also extends until 31 December 2047 the application period of the 100% corporate income tax deduction available for income derived from the export of financial services carried out within the IFC.
In addition, the exemption from financial activity fees under the Fees Law applicable to the headquarters and branches of financial institutions holding participant certificates within the IFC has been extended from five years to twenty years.
These amendments are intended to enhance the attractiveness of the IFC as a more predictable and competitive investment environment for international financial institutions and multinational enterprises.
Reduced Corporate Income Tax Rate for Manufacturing and Agricultural Production Activities
Pursuant to the amendment made to Article 32 of the Corporate Income Tax Law, the corporate income tax rate applicable to income derived exclusively from manufacturing activities carried out by corporations holding an industrial registration certificate and actively engaged in manufacturing, as well as income derived from agricultural production activities, has been reduced to 12.5%.
However, income benefiting from this reduced rate will not be eligible for the additional five-percentage-point corporate income tax reduction applicable to export income.
The amendment entered into force on the date of publication and will apply to income derived in the 2027 and subsequent taxation periods.
Revision of the Tax Exemption Applicable to Employee Share Incentive Schemes
Under Law No. 7524, which entered into force on 2 August 2024, shares granted free of charge or at a discount by employers qualifying as technology start-ups under criteria determined by the Ministry of Industry and Technology were exempt from income tax up to an amount equal to the fair market value of such shares not exceeding the employee’s annual gross salary.
Law No. 7582 increases this threshold to an amount equal to two times the employee’s annual gross salary.
The Law also revises the claw-back mechanism applicable upon disposal of such shares and introduces a more favourable regime for employees. Accordingly, where shares are disposed of:
- within two full years from the acquisition date, 100% of the exempted tax;
- between three and four years from the acquisition date, 75% of the exempted tax; and
- between five and six years from the acquisition date, 25% of the exempted tax,
shall be collected from the employer together with late payment interest, without the imposition of a tax loss penalty.
The amendment entered into force on the date of publication.
Extension of Deferral Periods for Public Receivables and Increase of the Instalment Threshold
The Law introduces significant flexibility for taxpayers in relation to the restructuring and collection of public receivables. Accordingly, the maximum deferral period for public receivables has been extended from 36 months to 72 months, while the threshold for receivables that may be deferred without requiring collateral has been increased from TRY 50,000 to TRY 1,000,000.
Conclusion
When considered as a whole, the amendments introduced by Law No. 7582 reflect a comprehensive economic policy aimed at strengthening Türkiye’s position within the international investment, finance, technology and services ecosystem.
In particular, the Qualified Service Centre regime, the incentives for transit trade activities, the additional advantages granted to the Istanbul Finance Centre, the exemptions introduced for foreign-source income and the reduced corporate income tax rate applicable to manufacturing activities collectively demonstrate Türkiye’s intention to position itself as a more competitive regional hub for management, financing, supply chain and high value-added service activities.
The new rules are expected to have significant implications for multinational groups, particularly in relation to group structures, service models, financing arrangements and employee incentive schemes.
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.
[View Source]