Proposed Tax Amendments in Türkiye

This tax alert summarizes the key provisions of the proposed tax amendments bill introducing significant changes to the Turkish tax legislation. The package includes comprehensive measures relating to tax collection, income tax, corporate income tax and investment incentives.

KEY HIGHLIGHTS

Tax Deferral Mechanism (Law No. 6183)

The maximum installment period for tax deferrals is increased from 36 months to 72 months. In addition, the threshold for deferrals without collateral is increased from TRY 50,000 to TRY 1,000,000.

Special Inheritance Tax Regime for Foreign Income Exemption Beneficiaries

For individuals benefiting from the income tax exemption on foreign-source income under Article 20/D (repeated) of the Income Tax Code, it is proposed that transfers of assets through inheritance during the exemption period will be subject to inheritance and gift tax at a rate of 1%.

Income Tax Exemption on Stock Options for Employees of Tech Startups

For shares granted to employees of technogirişim companies, the income tax exemption cap is increased to two times of the the annual gross salary in the relevant year.

If such shares are disposed of:

• within 2 years from acquisition → 100% of the exempted tax,
• within 3–4 years → 75%,
• within 5–6 years → 25%
• will be collected from the employer, together with late payment interest.

A Special Tax Regime for Those Individuals Not Residing in Türkiye During the Last 3 Calendar Years

It is proposed that foreign sourced income derived by qualifying individuals will be exempt from income tax. On the other hand Turkiye sourced income of these individuals will be taxable as per the general rules.

In this context, being a taxpayer in Türkiye during those years due to income from immovabe property, income from securities, and capital gains earned in Türkiye, shall not be considered a violation of the condition for benefiting from the said exemption. The regulation is expected to enter into force upon publication, to be applied for those individuals residing in Türkiye starting from 1 January 2026.

Qualified Service Personnel – Wage Tax Exemption

Wages paid to qualified personnel employed in qualified service centers will be exempt from income tax up to four times the gross minimum wage.

For entities operating within the Istanbul Finance Center (IFC), this threshold will be applied as six times the gross minimum wage. Such wages will also be exempt from stamp tax.

Qualified Service Centers

The proposal introduces the definition and operational criteria for qualified service centers. At least 80% of the annual revenue of these centers should derive from foreign related companies or group companies.

Corporate Income Tax Incentives – Transit Trade and Income of Qualified Service Centers

The corporate income tax deduction rate applicable to transit trade income for IFC participants is increased to 100%. For companies operating outside IFC, the deduction rate is set at 95%.

In addition, the same rates will apply to earnings of qualified service centers operating within and outside IFC. The regulation is expected to be applicable for earnings of fiscal years starting from 1 January 2026, and to corporate income tax returns to be filed as of 1 July 2026.

Reduced Corporate Income Tax Rates – Income from Exports

The general corporate income tax rate of 25% is proposed to be reduced as follows:

• 9% for manufacturing exporters
• 14% for other exporters

These rates are expected to apply to income derived in 2027 and subsequent tax periods.

Interaction with Domestic Minimum Corporate Income Tax

It is proposed that the corporate tax deductions applicable to transit trade, qualified service centers and financial service exports within IFC will also be deductible when calculating the domestic minimum corporate tax base. This provision is expected to apply to tax periods starting as of 1 January 2026, and to returns filed as of 1 July 2026.

Foreign Asset Repatriation (Wealth Amnesty)

Assets held abroad by real and legal persons, including cash, foreign currency, gold, shares, bonds and other securities, may be declared and brought into Türkiye until 31 July 2027.

Provided that the relevant conditions are met, such assets will not be subject to tax audit or assessment. The applicable tax rates are expected to vary depending on the holding period and investment type.

Entrepreneurship and Technology Ecosystem

Various incentives and facilitation measures are proposed to support technology and innovation-driven startups, particularly in relation to the establishment and financing of digital companies.

Expansion of Income Tax Incentive for the Employment of Personnel with Overseas Experience to all IFC Participants

It is proposed to introduce income tax incentives for employees with overseas experience employed by all IFC participants, which has been currently available only for IFC financial institutions.

Extension of Duration of Incentives for IFC Financial Institutions

The duration of the corporate income tax incentive applicable to financial institutions operating within IFC is extended until 2047. In addition, the exemption from financial activity fees is extended to 20 years.