01
Performed in Türkiye
The qualifying service has to be performed inside Türkiye by the Turkish entity. Pure resale of a service performed elsewhere does not qualify.
Evidence
Employment records, location of staff, project documentation.
Tax, Accounting & R&D
Service Export Tax Structure
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.
- 100% exemption
- Article 10/1-ğ
- VAT zero-rated
- Preserved vs minimum tax
What it is
Türkiye treats services delivered to non-resident customers and used outside Türkiye as service exports, and exempts the resulting income from corporate tax under Article 10/1-ğ of Corporate Tax Law No. 5520. The exemption rate has moved up over time: 50% before December 2023, 80% from the December 2023 reform under Law No. 7491, and 100% from April 2026 under Law No. 7553. It is the single biggest reason a foreign-owned studio runs its development entity in Türkiye rather than elsewhere in the region. The exemption is straightforward in principle but turns on four cumulative conditions, and the tax authority looks at each one when a return is examined. We design your contracts, banking flow, and invoicing so all four are evidenced cleanly the year you ship and every year after.
Four cumulative conditions
All four have to be met. Every invoice. Every year.
Article 10/1-ğ reads simply. Examination practice is unforgiving on each clause. The exemption is built around evidencing all four conditions for every invoice that claims it, every year.
02
Provided to a non-resident
The customer on the invoice has to be outside Türkiye. A Turkish permanent establishment of a foreign company counts as Turkish, not foreign.
Evidence
Service agreement, customer's tax residency, no Turkish PE.
03
Used outside Türkiye
The benefit of the service has to be enjoyed outside Türkiye. In-Türkiye consumption (events, hotel stays, services to local end users) does not qualify.
Evidence
Contract use-abroad clause, delivery method, customer location.
04
Revenue remitted to a Turkish bank
The foreign-currency receipt has to land in a Turkish bank account by the corporate-tax filing deadline (typically 30 April of the following year).
Evidence
Inbound SWIFT receipt, e-fatura cross-reference, bank confirmation.
The rate has moved
50% to 80% to 100% across three reforms in three years.
Türkiye keeps tilting toward this incentive because the studios that qualify generate foreign-currency receipts and high-value tech employment without subsidy. The April 2026 reform tightened the "used abroad" evidence requirements alongside the rate increase, which is why the structure has to be designed correctly on day one.
50%
Until December 2023
Original Article 10/1-ğ
Half of qualifying service-export income exempt from corporate tax.
80%
December 2023
Law No. 7491
Exemption raised to 80% as part of the December 2023 reform package.
100%
April 2026
Law No. 7553
Full exemption from fiscal year 2026 onward, with tightened evidence requirements.
How we do it
Design once. Defend every year.
The first year is design and setup. From year two, the same evidence file refreshes monthly and feeds the annual claim cleanly.
Eligibility design
We confirm your services are within the named sectors and that the four cumulative conditions are met against your real flow: performed in Türkiye, provided to a non-resident, used outside Türkiye, with revenue remitted to a Turkish bank account by the corporate-tax filing deadline. Borderline edges (cross-charges to a Turkish PE of the customer, free-zone counterparts, in-Türkiye consumption) flagged and structured around.
Contract architecture
The service agreement is the primary piece of evidence the tax authority looks at. We draft or review against the exemption criteria: customer's non-resident status warranted, place of performance and place of use defined, deliverables specified to evidence use abroad, currency and remittance mechanics aligned with the bank flow.
Banking flow
Service-export revenue must be transferred to a bank account in Türkiye by the corporate-tax filing deadline (30 April of the following year). We configure the foreign-currency sub-account binding so receipts land in original currency, with SWIFT correspondent routing pre-documented for your payors. Multi-currency banking and the service-export exemption are designed together, not separately.
Invoicing setup
E-fatura issued to the non-resident customer in their name, with VAT zero-rated under VAT Law Articles 11 and 12. E-arşiv used where the customer is outside the e-fatura system. Invoice line items and references designed to tie cleanly back to the contract and the inbound transfer.
Evidence file
A live evidence file maintained monthly by your CPA, tying each invoice to its contract, its inbound transfer, and the use-abroad evidence. Built so a Revenue Administration examination is answered with a single PDF instead of a six-month reconstruction.
Annual claim
At year-end, your CPA computes the exempted income and applies the deduction on the corporate tax return (Kurumlar Vergisi Beyannamesi) filed by 30 April. The deduction is preserved against the Domestic Minimum Tax base under Law No. 7524.
What's included
Design memo through audit defence.
- Eligibility assessment and design memo per service line
- Contract review or drafting against the four cumulative conditions
- Banking flow configuration for foreign-currency receipts
- E-fatura and e-arşiv setup with VAT zero-rating for non-resident customers
- Monthly evidence file tying each invoice to its contract and inbound transfer
- Annual deduction computation and claim on the corporate-tax return
- Domestic Minimum Tax interaction reviewed annually
- Audit-defence support if the Revenue Administration examines the claim
Key facts
Statutes, sectors, and what does not qualify.
- Legal basis
- Corporate Tax Law No. 5520 Article 10/1-ğ. Income Tax Law No. 193 Article 89/1-13 for sole proprietors. VAT zero-rating under VAT Law No. 3065 Articles 11 and 12.
- Exemption rate history
- 50% before December 2023. Raised to 80% from December 2023 under Law No. 7491. Raised to 100% from fiscal year 2026 under Law No. 7553 (April 2026 reform). Applies to qualifying service-export income for tax years from the effective date.
- Named sectors in the legislation
- Software, video gaming, engineering, architecture, design, education, medical services (telemedicine and health tourism), translation, accounting and tax consultancy, and certain repair-maintenance services. Game and app studios sit squarely inside the software / video gaming category.
- Four cumulative conditions
- (1) The service is performed in Türkiye. (2) It is provided to a customer outside Türkiye. (3) It is used outside Türkiye. (4) The revenue is transferred to a bank account in Türkiye by the corporate-tax filing deadline (typically 30 April of the following year).
- VAT zero-rating
- Service exports are zero-rated for VAT: no Turkish VAT on the export invoice, and input VAT on related Turkish costs (rent, software, equipment) is recoverable through the refund mechanism handled by our VAT Refund Recovery service.
- Preserved against Domestic Minimum Tax
- The 10% Domestic Minimum Tax introduced by Law No. 7524 (effective 2025) preserves the Article 10/1-ğ service-export exemption against the minimum-tax base. Studios qualifying for the exemption stay at near-zero effective corporate tax on qualifying income.
- What does not qualify
- Services used in Türkiye (whether the customer is local or foreign). Services to a permanent establishment of a non-resident in Türkiye. Sales to Turkish free-zone customers do not count as 'abroad' for this exemption. Pure goods trading. Tech-park income runs on its own separate Law 4691 regime.
- Interaction with other regimes
- Tech Development Zone (Law 4691) exemption and R&D Centre (Law 5746) deductions are separate. A studio operating in a tech-park typically claims the Law 4691 exemption on qualifying zone activity and the Article 10/1-ğ exemption on out-of-zone service-export activity. We model the interaction during onboarding.
Bundled in
- StarterOptional
- Builder✓
- Enterprise✓
Pricing
Included in ongoing retainer for Builder and Enterprise. Standalone annual review: USD 2,400, which also covers the year's annual claim preparation and Revenue Administration correspondence.
Related services
Bookkeeping & Tax Filings
Monthly bookkeeping under the Turkish Uniform Chart of Accounts, every statutory filing on its statutory date, run by a licensed Turkish CPA on the e-fatura and e-defter rails. Built so your investors and your CFO can read it.
Learn more
Multi-Currency Banking
TRY, USD, and EUR sub-accounts under one corporate banking relationship. Receive in the original currency, convert on your timing, evidence the service-export exemption.
Learn more
IP & Royalty Agreements
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.
Learn more
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