IP, Contracts & Privacy
The intercompany agreements that move IP and revenue between your HQ and the Turkish entity. Arm's-length, bilingual, treaty-aware, and designed to keep the service-export exemption clean.
What it is
Foreign-owned game and app studios in Türkiye almost always run an intercompany flow: the HQ owns the IP, the Turkish LTD develops or operates it, and money crosses the border in one direction or another. The agreements that govern this flow do three things at once. They set the transfer price under Article 13 of the Corporate Tax Law (and the OECD Guidelines it tracks). They control the withholding tax on royalties and service fees through the relevant double-taxation treaty. They evidence the conditions of the 100% service-export tax exemption under Article 10/1-ğ. Get them wrong on day one and you spend years explaining the structure to two tax authorities at once. We pick the right archetype for your studio, draft it bilingually so it survives a Turkish court, and align the pricing with the transfer-pricing study your CPA files annually.
Two agreement archetypes
The choice depends on who owns the IP, who commercialises it, and where the customer pays. Most studios run one. Some run both, or a hybrid. We pick on the discovery call.
Three things at once
The transfer-pricing position has to match the agreement. The withholding-tax mechanic has to match the treaty. The service-export exemption has to match the invoicing and banking flow. Get one of the three wrong and you spend years explaining the structure to two tax authorities at once. We draft so all three agree on day one.
Article 13
Transfer pricing. All related-party flows at arm's length, OECD-aligned.
Treaty
Withholding tax on royalties reduced under the relevant double-taxation treaty.
Article 10/1-ğ
The 100% service-export corporate-tax exemption on qualifying income.
How we do it
The agreements live alongside the bookkeeping, the banking flow, and the annual tax return. We hand the package over to your CPA as one piece, not five.
Flow mapping
We map the value chain: who owns the IP, who develops it, who exploits it commercially, where the customer pays, and where the cash settles. We identify each related-party transaction (services, royalties, cost recharges, financing) and decide which agreement covers it.
Archetype selection
Two main archetypes. Development Services Agreement: HQ owns the IP, the Turkish LTD performs development work, HQ pays a service fee. IP Licence Agreement: HQ owns the IP, the Turkish LTD licenses it to commercialise, and pays a royalty. Many studios run both, or a hybrid. We pick what fits your value chain and your tax position.
Pricing methodology
Methodology chosen against the OECD/Article 13 standard. Development services typically priced cost-plus under TNMM (Transactional Net Margin Method); royalties typically priced against CUP (Comparable Uncontrolled Price) where benchmarks exist. The methodology is scoped in the agreement so it survives examination.
Bilingual drafting
Drafted in English with a Turkish counterpart, signed in both languages with the Turkish version controlling for Turkish-court enforceability. Service-export evidence clauses, currency, payment timing, IP ownership warranties, termination, and dispute resolution all included.
Filings and coordination
Stamp tax handled where applicable. Central Bank notifications coordinated for certain royalty flows under Decree 32. Pricing benchmarks handed off to your CPA for the annual transfer-pricing file and the transfer-pricing form filed with the corporate-tax return.
What's included
Key facts
Bundled in
Pricing
Included in Builder and Enterprise. Standalone scoped per studio, depending on archetype, number of agreements, and complexity of the intercompany flow.
Related services
The arm's-length study, the annual file, and the form filed with your corporate-tax return. Built to OECD and Article 13 standards so the Revenue Administration finds nothing to adjust.
Türkiye's headline incentive for foreign-facing software and gaming studios: a 100% corporate-tax exemption on qualifying service-export income under Article 10/1-ğ. The contract structure, banking flow, and bookkeeping designed to qualify every year, not just the first.
Decide who holds the shares of your Turkish company. A person, another company you own, or Turquo on your behalf.
Free 30-minute discovery call. We'll match the right services to your stage and come back with a fixed-fee proposal.
