Communiqué Amending the General Corporate Income Tax Communiqué (Serial No. 1) (Serial No. 26)

The Communiqué Amending the General Corporate Income Tax Communiqué (Serial No. 1) (Serial No. 26), published in the Official Gazette dated 4 July 2026 and numbered 33300, provides significant guidance on the implementation of the amendments introduced to the Corporate Income Tax Code through Law No. 7577 and Law No. 7582.

In particular, the Communiqué provides detailed explanations regarding:

• The scope of the corporate income tax exemption applicable to healthcare institutions operated by foundation universities
• The corporate income tax deduction applicable to income derived from the sale of goods purchased abroad and sold abroad without being brought into Türkiye, as well as income derived from intermediary activities relating to the purchase and sale of goods abroad
• The corporate income tax deduction available for income generated by qualified service centres from services provided to non-residents
• The 12.5% corporate income tax rate applicable to income derived from manufacturing and agricultural production activities
• The treatment of toll manufacturing activities under the reduced corporate income tax regime
• The simultaneous application of different reduced corporate income tax rates to income derived from manufacturing and export activities; and
• The implementation of the domestic minimum corporate income tax

In this Tax Alert, we summarise the amendments introduced by the Communiqué within the framework of the implementation guidance and the illustrative examples provided therein.

Conditions for Benefiting from the Deduction

The Communiqué provides that the following conditions must be satisfied cumulatively in order to benefit from the deduction:

• The goods subject to the transaction must be purchased abroad
• The goods must not be physically brought into Türkiye
• The goods must subsequently be sold to customers abroad, or the intermediary activity relating to the purchase and sale of the goods must be carried out entirely outside Türkiye
• In the case of intermediary activities, both the purchaser and the seller must be non-residents of Türkiye
• The relevant income must be transferred to Türkiye by the deadline for filing the corporate income tax return; and
• The income subject to the deduction must be separately disclosed in the corporate income tax return

The Communiqué further clarifies that only business income derived from these qualifying activities falls within the scope of the deduction. Accordingly, interest income, foreign exchange gains, dividend income and other income items that are not directly related to the relevant activities will not be taken into account in calculating the deductible amount.

Illustrative Example 1 – Income Derived from Transit Trade

In the first example provided in the Communiqué, A Inc., a company resident in Türkiye, purchases goods from a manufacturer resident in Germany and resells them to another company resident in Egypt without bringing the goods into Türkiye.

As a result of this transaction, the company earns TRY 1,000,000 and transfers the relevant income to Türkiye before the deadline for filing its corporate income tax return.

According to the Communiqué:

• The goods were never brought into Türkiye;
• The sale took place entirely outside Türkiye; and
• The income was transferred to Türkiye within the prescribed period

Accordingly, 95% of the income derived from the transaction, i.e. TRY 950,000, may be deducted from the corporate income tax base.

Consequently, the company will calculate corporate income tax only on the remaining TRY 50,000.

Illustrative Example 2 – Intermediary Activities Relating to the Purchase and Sale of Goods Abroad

In the second example provided in the Communiqué, C Inc., a company resident in Istanbul, acts as an intermediary in the sale of goods between a seller resident in Egypt and a purchaser resident in France.

The company earns an intermediary commission of TRY 400,000 from this activity and transfers the relevant income to Türkiye by the deadline for filing its annual corporate income tax return.

According to the Communiqué:

• The intermediary activity is carried out entirely outside Türkiye
• Neither the purchaser nor the seller is resident in Türkiye
• The company acts solely as an intermediary; and
• The income derived from the activity is transferred to Türkiye within the prescribed period

Since all of these conditions are satisfied, 95% of the intermediary commission income, amounting to TRY 380,000, may be deducted from the corporate income tax base. Accordingly, only TRY 20,000 will remain subject to corporate income tax.

Illustrative Example 3 – 100% Deduction for Istanbul Financial Centre Participants

In the third example, C Inc., operating in the Istanbul Financial Centre under a valid participant certificate, purchases goods from a company resident in Japan and resells them to a company resident in the United Arab Emirates without bringing the goods into Türkiye.

The company earns TRY 2,000,000 from the transaction and transfers the entire amount to Türkiye within the period prescribed for filing the corporate income tax return.

Although the general deduction rate applicable to this type of activity is 95%, the special rule set out in the Communiqué applies because the company operates in the Istanbul Financial Centre under a participant certificate.

Accordingly, the company will be entitled to deduct 100% of the income, amounting to TRY 2,000,000, from its corporate income tax base.

Through this example, the Communiqué illustrates the application of the additional incentive introduced for participants operating in the Istanbul Financial Centre.

Illustrative Example 4 – Circumstances Where the Deduction Cannot Be Applied

The fourth example in the Communiqué illustrates a situation in which the deduction is not available.

In this example, A Inc. purchases goods from a company resident in Germany and brings the goods into a bonded warehouse in Türkiye before subsequently selling them to a customer resident in France.

Although the sale is made to a customer located abroad, one of the fundamental statutory conditions is not satisfied because the goods are physically brought into Türkiye.

Accordingly, the 95% corporate income tax deduction cannot be applied to the income derived from this transaction.

Through this example, the Communiqué clearly demonstrates that where the goods are physically brought into Türkiye, the taxpayer cannot benefit from the deduction, even if the goods are subsequently sold abroad.

Determination of the Income Eligible for the Deduction

The Communiqué also provides detailed guidance on the principles and procedures for determining the amount of income eligible for the deduction.

Accordingly, the income forming the basis of the deduction shall be calculated by deducting the costs and expenses directly attributable to the qualifying activities from the revenue generated from such activities.

Taxpayers carrying out both qualifying and non-qualifying activities are required to maintain their accounting records in a manner that enables the separate tracking of:

• Revenues;
• Costs; and
• Operating expenses

attributable to each activity.

Accordingly, only the actual income attributable to the qualifying activities will be taken into account in calculating the deductible amount.

Income Not Eligible for the Deduction

The Communiqué further expressly provides that, although derived by taxpayers carrying out qualifying activities, the following types of income will not be included in the calculation of the deduction:

• Non-operating income
• Interest income on bank deposits
• Repo income
• Foreign exchange gains
• Gains derived from the disposal of shareholdings
• Gains derived from the disposal of fixed assets; and
• Other extraordinary income and gains

Accordingly, only the business income derived from transit trade or intermediary activities relating to the purchase and sale of goods abroad will qualify for the corporate income tax deduction.

Determination of Income Derived from Manufacturing Activities

The Communiqué provides that the reduced corporate income tax rate applies to income derived from manufacturing activities. Accordingly, the income attributable to manufacturing activities must first be accurately determined.

Where a taxpayer carries out more than one manufacturing activity, the income derived from all manufacturing activities shall be assessed collectively, taking into account any losses arising from such activities. Accordingly, the net income derived from all manufacturing activities will constitute the basis for applying the 12.5% corporate income tax rate.

Where the taxpayer derives income both from manufacturing activities and from other non-manufacturing activities, the portion of the corporate income tax base eligible for the reduced corporate income tax rate shall be calculated by reference to the proportion of the income derived from manufacturing activities to the accounting profit.

The Communiqué illustrates this calculation using the following formula:

Tax Base Subject to the Reduced Corporate Income Tax Rate = Corporate Income Tax Base × (Income Derived from Manufacturing Activities / Accounting Profit)

The 12.5% corporate income tax rate will apply to the tax base calculated in accordance with this formula, while the remaining portion of the corporate income tax base will be subject to the general corporate income tax rate.

Illustrative Example 1

In the first example provided in the Communiqué, F Inc., a company holding a valid Industrial Registration Certificate, derives TRY 1,400,000 from its manufacturing activities and TRY 600,000 from its non-manufacturing activities during the 2027 fiscal year.

The company's financial information is as follows:

• Accounting profit: TRY 2,000,000
• Non-deductible expenses: TRY 500,000
• Tax losses carried forward: TRY 1,200,000
• Corporate income tax base: TRY 1,300,000

According to the calculation set out in the Communiqué, the tax base eligible for the reduced corporate income tax rate is calculated as follows:

Tax Base Subject to the Reduced Rate

= TRY 1,300,000 × (TRY 1,400,000 / TRY 2,000,000)

= TRY 910,000

Accordingly:

• The 12.5% corporate income tax rate will apply to TRY 910,000; and
• The general corporate income tax rate will apply to the remaining TRY 390,000.

Illustrative Example 2

In the second example, G Inc., a company holding a valid Industrial Registration Certificate, carries out two different manufacturing activities.

The company derives:

• TRY 3,800,000 of income from the sale of agricultural machinery;
• TRY 1,200,000 of loss from the sale of healthcare products; and
• TRY 1,800,000 of loss from another manufacturing activity.

Accordingly, the overall result of the manufacturing activities is taken into account as a net manufacturing income of TRY 800,000.

The company's financial information is as follows:

• Accounting profit: TRY 2,000,000
• Corporate income tax base: TRY 1,000,000

The tax base eligible for the reduced corporate income tax rate is calculated as follows:

TRY 1,000,000 × (TRY 800,000 / TRY 2,000,000) = TRY 400,000

Accordingly:

• The 12.5% corporate income tax rate will apply to TRY 400,000; and
• The general corporate income tax rate will apply to the remaining TRY 600,000

Through this example, the Communiqué specifically emphasizes that losses arising from different manufacturing activities must be offset against each other in determining the net manufacturing income eligible for the reduced corporate income tax rate.

Application of the Reduced Corporate Income Tax Rate Where Both Manufacturing and Export Activities Are Carried Out

The Communiqué also contains important guidance regarding the application of the reduced corporate income tax rate to taxpayers engaged in both manufacturing and export activities.

Accordingly, for corporations holding a valid Industrial Registration Certificate and actively engaged in manufacturing activities:

• Income derived from the domestic sale of products manufactured by the taxpayer; and
• Income derived from the export of products manufactured by the taxpayer,
• Will both be regarded as income derived from manufacturing activities

However, where the exported products are not manufactured by the taxpayer but are instead purchased from third parties and subsequently exported, the income derived from such exports will not be regarded as income derived from manufacturing activities. In such cases, only the corporate income tax incentive applicable to export income may be applied.

The Communiqué further explains, through illustrative examples, the principles governing the simultaneous application of the 12.5% corporate income tax rate applicable to manufacturing income and the five-percentage-point corporate income tax reduction applicable to export income.

Illustrative Example 1 – Export of a Portion of Self-Manufactured Products

In the first example provided in the Communiqué, H Inc., a company holding a valid Industrial Registration Certificate and engaged in the manufacture of bags, sells a portion of its self-manufactured bags in the domestic market and exports the remaining portion.

The company's operating results for the 2027 fiscal year are as follows:

• Income from domestic sales: TRY 400,000
• Income from exports: TRY 600,000
• Accounting profit: TRY 1,000,000

According to the Communiqué, since both the domestic sales income and the export income are derived from the taxpayer's own manufacturing activities, the 12.5% corporate income tax rate will apply to the entire income of TRY 1,000,000.

However, no additional five-percentage-point corporate income tax reduction applicable to export activities will be available in respect of the TRY 600,000 export income. Accordingly, the entire income derived from the manufacturing activity will be subject to the 12.5% corporate income tax rate. In other words, the income derived from self-manufactured products that are subsequently exported will not benefit from a cumulative 17.5 percentage-point tax reduction.

Illustrative Example 2 – Separate Income Derived from Manufacturing and Export Activities

In the second example provided in the Communiqué, I Inc., a company holding a valid Industrial Registration Certificate, sells a portion of its self-manufactured heating systems in the domestic market and exports the remaining portion. The company's financial information for the 2027 fiscal year is as follows:

• Accounting profit: TRY 3,000,000
• Income derived from domestic sales: TRY 900,000
• Income derived from exports of self-manufactured products: TRY 1,500,000
• Other income (not eligible for the reduced rate): TRY 600,000
• Non-deductible expenses: TRY 200,000
• Tax losses carried forward: TRY 1,200,000
• Corporate income tax base: TRY 2,000,000

The Communiqué expressly states that where income derived from manufacturing activities is also generated through the export of self-manufactured products, no additional five-percentage-point reduction applicable to export income may be applied in addition to the reduced rate available for manufacturing activities. In other words, the relevant income does not benefit from a cumulative 17.5 percentage-point tax reduction.

Accordingly, the portion of the corporate income tax base attributable to manufacturing activities is first calculated as follows:

Tax Base Subject to the Reduced Rate = Corporate Income Tax Base × (Income Derived from Manufacturing Activities / Accounting Profit)

Based on this formula:

TRY 2,000,000 × (TRY 2,400,000 / TRY 3,000,000) = TRY 1,600,000

The 12.5% corporate income tax rate (i.e. 25% – 12.5%) will apply to the calculated tax base of TRY 1,600,000, as it relates to income derived from manufacturing activities. The remaining TRY 400,000 of the corporate income tax base will be taxed at the general corporate income tax rate.

This example further demonstrates that no additional five-percentage-point reduction applicable to export activities is available in respect of income derived from self-manufactured products that are exported.

Illustrative Example 3 – Simultaneous Manufacturing and Export of Non-Manufactured Products

In the third example provided in the Communiqué, J Inc., a company holding a valid Industrial Registration Certificate, manufactures construction machinery and hardware products while also carrying out trading activities involving white goods. The company sells its construction machinery in the domestic market, exports its hardware products, and exports white goods purchased from third parties.

The company's operating results for the 2027 fiscal year are as follows:

• Accounting profit: TRY 2,000,000
• Income from the sale of construction machinery: TRY 800,000
• Loss arising from the export of hardware products: TRY 400,000
• Income from the export of white goods: TRY 1,000,000
• Other income (not eligible for the reduced rate): TRY 600,000
• Non-deductible expenses: TRY 500,000
• Tax losses carried forward: TRY 1,200,000
• Corporate income tax base: TRY 1,300,000

According to the Communiqué:

The company's net manufacturing income is determined by taking into account both the TRY 800,000 income derived from the sale of construction machinery and the TRY 400,000 loss arising from the export of hardware products, resulting in net manufacturing income of TRY 400,000.

The TRY 1,000,000 income derived from the export of white goods is not regarded as income derived from manufacturing activities because the exported products were not manufactured by the taxpayer. However, as the income is derived from export activities, it may benefit from the corporate income tax reduction applicable to export income.

Accordingly, based on the formula set out in the Communiqué:
Tax Base Subject to the Reduced Rate (Manufacturing Activities):

TRY 1,300,000 × (TRY 400,000 / TRY 2,000,000) = TRY 260,000

Accordingly:

• The 12.5% corporate income tax rate will apply to the TRY 260,000 tax base attributable to manufacturing activities

In addition, the portion of the corporate income tax base attributable to the export of purchased white goods is calculated separately.

Accordingly:

Tax Base Attributable to Export Activities:

TRY 1,300,000 × (TRY 1,000,000 / TRY 2,000,000) = TRY 650,000

As a result:

• The five-percentage-point reduced corporate income tax rate applicable to export income (20%) will apply to the TRY 650,000 tax base attributable to export activities
• The 12.5% corporate income tax rate will apply to the TRY 260,000 tax base attributable to manufacturing activities; and
• The remaining TRY 390,000 of the corporate income tax base will be taxed at the general corporate income tax rate

Through this example, the Communiqué clearly demonstrates that where a taxpayer simultaneously carries out manufacturing activities and exports products not manufactured by itself, the reduced corporate income tax incentives applicable to each activity must be calculated separately.

Application of the Reduced Corporate Income Tax Rate to Publicly Held Companies

The Communiqué also provides guidance on the application of the 2-percentage-point corporate income tax reduction available to publicly held companies following the amendments made to Article 32 of the Corporate Income Tax Code, and explains how this incentive interacts with the reduced corporate income tax rates applicable to manufacturing and export activities.

Accordingly, corporations whose shares are offered to the public for the first time and at least 20% of whose shares are listed on the Borsa Istanbul Equity Market may benefit from a 2-percentage-point reduction in the corporate income tax rate for five fiscal years, commencing from the fiscal year in which the initial public offering takes place.

The Communiqué further clarifies that the reduced corporate income tax rates applicable to:

• Income derived from manufacturing activities; and
• Income derived from export activities

will be applied after taking into account the 2-percentage-point reduction available to publicly held companies. In other words, these incentives will be applied cumulatively to the same portion of the tax base.

Illustrative Example

In the example provided in the Communiqué, N Inc., a company holding a valid Industrial Registration Certificate whose shares were offered to the public for the first time in 2025, derives TRY 1,400,000 of income from its manufacturing activities during the 2027 fiscal year.

The company's financial information is as follows:

• Corporate income tax base: TRY 500,000
• Accounting profit: TRY 2,000,000

Accordingly, the portion of the corporate income tax base attributable to the manufacturing activity is calculated as follows:

TRY 500,000 × (TRY 1,400,000 / TRY 2,000,000) = TRY 350,000

According to the Communiqué:

• The company's corporate income tax rate is first reduced by 2 percentage points, resulting in a 23% corporate income tax rate, due to its publicly held status
• Subsequently, the 12.5% corporate income tax rate applicable to manufacturing income is applied to the portion of the tax base attributable to the manufacturing activity

Accordingly:

• The 12.5% corporate income tax rate will apply to the TRY 350,000 tax base attributable to the manufacturing activity; and
• The 23% corporate income tax rate applicable to publicly held companies will apply to the remaining TRY 150,000 of the corporate income tax base

New Deductible Items in the Calculation of the Domestic Minimum Corporate Income Tax Base

In the final section of the Communiqué, the explanations regarding the domestic minimum corporate income tax have been updated.

Pursuant to the amendments introduced by Law No. 7582, the following items may be deducted in calculating the domestic minimum corporate income tax base:

• Income derived from the resale abroad of goods purchased abroad without being brought into Türkiye, or from intermediary activities relating to the purchase and sale of goods carried out abroad, which is deducted from the corporate income tax base pursuant to Article 10/1(i) of the Corporate Income Tax Law
• Income derived exclusively from services provided abroad by qualified service centres, which is deducted from the corporate income tax base pursuant to Article 10/1(j) of the Corporate Income Tax Law; and
• Amounts deducted from the corporate income tax base under the exemption applicable to the export of financial services.

Through this amendment, the Communiqué clarifies that the above-mentioned deductions will be taken into account not only in the calculation of the corporate income tax base but also in the calculation of the domestic minimum corporate income tax base.