Regarding the Amendments Introduced by Law No. 7582 on Amendments to Certain Laws

Law No. 7582 on Amendments to Certain Laws (the “Law”), published in the Official Gazette dated 4 June 2026 and numbered 33270, has introduced significant amendments to various statutes, primarily including the Law No. 6183 on the Procedure for the Collection of Public Receivables (“LPCPR”), the Income Tax Law No. 193 (“ITL”), the Inheritance and Transfer Tax Law No. 7338 (“ITTL”), the Corporate Tax Law No. 5520 (“CTL”), the Foreign Direct Investment Law No. 4875 (“FDIL”), the Law No. 5746 on the Support of Research, Development and Design Activities (“R&D Law”), and the Istanbul Finance Center Law No. 7412 (“IFCL”).

The key amendments are summarized below:

• The deferral period applicable to public debts and the amounts eligible for deferral have been increased.
• A complementary tax advantage has been provided in connection with the income tax exemption applicable to foreign-sourced income and gains of real persons who settle in Türkiye under certain conditions.
• The provision of higher-value share-based benefits to employees of tech-startup companies has been made more favorable from a tax perspective.
• Certain amendments have been introduced to support employee retention and share-based incentive models, particularly in tech-startup companies qualifying as start-ups and scale-ups.
• It has been stipulated that real persons who had no domicile and no tax liability in Türkiye during the last three calendar years preceding the date on which they are deemed resident in Türkiye may benefit from an income tax exemption for a period of 20 years in respect of their income and gains derived outside Türkiye, and a provision has been added stipulating that expenses and costs relating to income and gains falling within the scope of the exemption shall not be taken into account in determining taxable income and gains.
• A new income tax exemption has been introduced for the wages of qualified service personnel employed in qualified service centers within the scope of the FDIL.
• It has been regulated that 95% of the income derived from the sale abroad of goods purchased from abroad without being brought into Türkiye, or from acting as an intermediary in purchase and sale transactions of goods carried out abroad, may be deducted from corporate income.
• It has been stipulated that 95% of the income derived from abroad by corporations operating as qualified service centers, exclusively within the scope of such activities, may be deducted from corporate income, and that they may benefit from an income tax exemption for a period of 20 years in respect of their income and gains derived outside Türkiye.
• The corporate income tax rate applicable to income derived from manufacturing and agricultural production activities has been re-determined.
• The scope of deductions and exemptions to be taken into account under the domestic minimum corporate income tax regime has been expanded.
• Real persons and legal entities have been allowed to declare money, gold, foreign currency, securities and other capital market instruments held abroad to banks or intermediary institutions until 31 July 2027.
• It has been regulated that the tax paid within the scope of the asset declaration mechanism may not, under any circumstances, be recorded as an expense or offset against any other tax.

The application terms and conditions of the relevant regulations are presented below for your attention.

Amendments to the Law No. 6183 on the Procedure for the Collection of Public Receivables

The Law first amends Article 48 of the LPCPR regarding the deferment of public receivables. In this context, the maximum deferment period for public receivables has been extended from 36 months to 72 months; in addition, the amount that may be deferred without collateral has been increased from TRY 50,000 to TRY 1,000,000. This amendment provides debtors facing difficulties in paying public debts with the opportunity for longer-term payment plans and a higher threshold for unsecured deferment. This amendment entered into force on the date of publication in the Official Gazette.

Amendments to the Inheritance and Transfer Tax Law No. 7338

With the amendment made to Article 16 of the ITTL, a special inheritance and transfer tax rate has been introduced for persons benefiting from the income tax exemption under duplicated Article 20/D added to the ITL. Accordingly, for transfers of assets by inheritance occurring within the period prescribed for the relevant exemption, the tax rate will be applied as 1%. This amendment constitutes a complementary tax advantage related to the income tax exemption applicable to foreign-source earnings and revenues of individuals settling in Türkiye under certain conditions. This provision entered into force on the date of publication in the Official Gazette.

Amendments to the Income Tax Law No. 193

• The amendment to Article 17 of the ITL expands the scope of the wage exemption applicable to benefits granted to employees through the issuance of shares. The relevant provision regulates the income tax exemption applicable to shares granted free of charge or at a discount by technopreneurship companies meeting the criteria determined by the Ministry of Industry and Technology, where such shares are deemed to constitute wages. Pursuant to the amendment, the upper limit of the benefit eligible for exemption has been increased from the employee’s one-year gross salary for the relevant year to an amount corresponding to two times such annual amount. In this way, providing employees of technopreneurship companies with higher-value share-based benefits has become more advantageous from a tax perspective.
• Under the same provision, the periods relating to the collection from the employer, together with default interest, of the tax previously exempted where the shares granted to employees are disposed of within certain periods have also been shortened. Under the previous regime, the full amount of the exempted tax was collected from the employer if the shares were disposed of within three full years; 75% if disposed of within four to six years; and 25% if disposed of within seven to twelve years. Under the new regulation, these periods have been revised to two full years, three to four years, and five to six years, respectively. Accordingly, if the shares are disposed of within two full years from the date of acquisition, the full amount of the exempted tax; if disposed of within three to four years, 75%; and if disposed of within five to six years, 25%, will be collected from the employer together with default interest, without the application of a tax loss penalty. This amendment is considered to support employee retention and share-based incentive models, particularly in technopreneurship companies with start-up and scale-up characteristics. This amendment entered into force on the date of publication in the Official Gazette.
• Pursuant to duplicated Article 20/D added to the ITL, individuals who did not have residence or tax liability in Türkiye during the last three calendar years before being deemed resident in Türkiye are entitled to benefit from an income tax exemption for a period of 20 years with respect to earnings and revenues obtained outside Türkiye. Within this scope, no annual income tax return will be filed in respect of earnings and revenues obtained by such persons outside Türkiye; and if a return is filed due to other income, such foreign-source earnings and revenues will not be included therein.
• However, it has been stipulated that expenses and costs relating to earnings and revenues covered by the exemption shall not be taken into account in determining taxable earnings and revenues. Furthermore, taxes paid in foreign countries due to such exempt earnings and revenues may not be credited against income tax assessed in Türkiye. If it is subsequently determined that the conditions for the exemption were not satisfied, the taxes that were not accrued will be deemed to have caused tax loss. This amendment entered into force on the date of publication to apply to individuals deemed resident in Türkiye as of 1/1/2026.
• The amendment to Article 23 of the ITL introduces a new income tax exemption for the wages of qualified service personnel employed in qualified service centres as defined under the FDIL. Accordingly, the portion of the wages of qualified service personnel working in qualified service centres that does not exceed three times the gross minimum wage shall be exempt from income tax. In respect of qualified service centres operating in industrial zones established under the Industrial Zones Law No. 4737 and deemed appropriate by the President according to the foreign investment intensity of the zone, as well as qualified service centres operating in the Istanbul Finance Center upon obtaining a participant certificate, this threshold shall apply as five times the gross minimum wage. The President has been authorized to decrease such threefold and fivefold amounts, jointly or separately, down to one time and to increase them up to two times. This amendment entered into force on the date of its publication in the Official Gazette.

Amendments to the Foreign Direct Investment Law No. 4875

A new provision added to the FDIL introduces the concept of a “qualified service centre” into the legislation. Accordingly, capital companies established to provide services to affiliated companies or group of companies actively operating in at least three different countries and generating at least 80% of their annual revenue from affiliated companies or a group of companies abroad, are defined as qualified service centres. It has been regulated that such centres may provide intra-group services such as financial advisory, strategic management consultancy, risk management, budgeting, financial reporting, audit, digital transformation, technology consultancy, investment and data analysis, legal consultancy, brand management, human resources, training, sales, after-sales support, technical support, R&D coordination, and similar services. It is further stated that legal consultancy services relating to Turkish law or domestic operations may only be procured from lawyers or law partnerships authorized to provide services under the Attorneyship Law No. 1136. Employees who directly perform these services and who are not support personnel are deemed “qualified service personnel.” This amendment entered into force on the date of its publication in the Official Gazette.

Amendments to the Corporate Tax Law No. 5520

• The amendment to Article 10 of the CTL provides that 95% of the gains derived from the offshore sale of goods purchased from abroad without being brought into Türkiye, or from intermediary activities relating to the purchase and sale of goods carried out abroad, may be deducted from corporate income. For corporations operating in industrial zones established under the Industrial Zones Law No. 4737 and deemed appropriate by the President according to the foreign investment intensity of the zone, as well as corporations operating in the Istanbul Finance Center Region upon obtaining a participant certificate under the IFCL, this rate shall apply as 100%. In order to benefit from this deduction, the gain must have been transferred to Türkiye by the deadline for filing the annual corporate tax return for the accounting period in which it was earned, and both the seller and the buyer of the goods subject to the intermediary activity must be located outside Türkiye. The President is authorized to reduce such rates to zero and increase them up to 100%.
• A new subparagraph added to the same article stipulates that 95% of the gains obtained from abroad exclusively within the scope of the activities of corporations operating as qualified service centres may be deducted from corporate income. For qualified service centres operating in zones established within the scope of industrial zones and deemed appropriate by the President, as well as corporations operating as qualified service centres in the Istanbul Finance Center Region upon obtaining a participant certificate, this rate shall apply as 100%. Subject to the condition that the gain is transferred to Türkiye by the deadline for filing the annual corporate tax return for the relevant accounting period, such deduction shall apply for 20 accounting periods starting from the accounting period in which the qualified service centre commences operations. The President is authorized to reduce these rates to 50% and increase them up to 100%. This amendment entered into force on its date of publication, to be effective for corporate earnings pertaining to the taxation period starting from 1/1/2026 (for corporations assigned a special accounting period, the accounting period starting from 1/1/2026) and beginning with the tax returns that must be submitted as of 1/7/2026.
• The amendment to Article 32 of the CTL redetermined the corporate tax rate applicable to gains derived from manufacturing and agricultural production activities. Accordingly, the corporate tax rate shall be applied as 12.5% in respect of gains derived exclusively from manufacturing activities by corporations holding an industrial registry certificate and actually engaged in manufacturing, as well as gains derived exclusively from agricultural production activities by corporations engaged in such agricultural production. In addition, no further deduction under the seventh paragraph of Article 32 of the CTL shall apply to gains benefiting from the reduced rate within this scope. This regulation shall apply to gains derived in the 2027 taxation period and subsequent taxation periods. This amendment entered into force on the date of publication, shall apply to gains derived in the 2027 taxation period and subsequent taxation periods; and for corporations subject to a special accounting period, to gains derived in the special accounting period beginning in the 2027 calendar year and subsequent taxation periods.
• The amendment to Article 32/C of the CTL expands the scope of deductions and exemptions to be considered under the domestic minimum corporate tax regime. In this context, the former reference made only to certain subparagraphs of the first paragraph of Article 10 of the CTL has been revised so as to also cover the newly added deductions for transit trade and qualified service centres. In addition, the earnings deduction set out in subparagraph (a) of the first paragraph of Article 6 of the IFCL has been added to the items to be taken into account for purposes of the domestic minimum corporate tax. This amendment entered into force on the date of publication, to apply starting with returns required to be filed as of 1/7/2026, and for corporate earnings relating to taxation periods beginning on or after 1/1/2026 (or, for corporations assigned a special accounting period, accounting periods beginning on or after 1/1/2026).
• A new asset declaration regime has been introduced through provisional Article 19 added to the CTL. In this scope, real persons and legal entities may notify banks or intermediary institutions of cash, gold, foreign currency, securities and other capital market instruments held abroad until 31 July 2027. The declared assets must be transferred, within two months from the date of declaration, to accounts opened in the name of the declaring persons at banks or intermediary institutions in Türkiye, or assets physically brought from abroad must be deposited into such accounts. The bringing into Türkiye of assets physically brought from abroad shall be substantiated by documents relating to the declaration to be made to the Customs Administration.

In addition, cash, gold, foreign currency, securities and other capital market instruments owned by income or corporate taxpayers and located in Türkiye but not recorded in their statutory books may also be notified to banks or intermediary institutions until 31 July 2027. It is mandatory to substantiate such assets by depositing them with banks or intermediary institutions as of the declaration date. Assets declared in this manner must be recorded in the statutory books as of the declaration date by taxpayers keeping books under the Tax Procedure Law No. 213. For taxpayers keeping books on the balance sheet basis, a special reserve account shall be opened on the liabilities side for such assets; such reserve account may not be withdrawn from the business until two years have elapsed from the declaration date and may not be used for any purpose other than capital addition.

• Persons without income or corporate tax liability may also benefit from the relevant regulation, provided that they bring their assets located abroad to Türkiye within the prescribed period or substantiate their domestic assets by depositing them with banks or intermediary institutions as of the declaration date. Banks and intermediary institutions shall, in their capacity as withholding agents, declare and pay by the evening of the fifteenth day of the month following the declaration the tax collected in advance from the declarant at the rate of 5% over the value of the assets notified to them. However, where it is undertaken that the declared asset will be maintained for certain periods in time deposit accounts, domestic government debt securities, lease certificates, or venture capital investment funds, the tax rate shall vary between 0% and 4% depending on the committed holding period. For declarations made between 1 January 2027 and 31 July 2027, a 0.5 percentage point increase shall apply to these rates.
• The tax paid within the scope of the asset declaration may in no way be treated as an expense and may not be credited against any other tax. Losses arising from the disposal of assets subject to the declaration shall likewise not be accepted as expenses or deductions for income tax or corporate tax purposes. Provided that the conditions set out in the regulation are complied with, no tax inspection or tax assessment shall be carried out in relation to the amounts corresponding to the declared assets. However, this protection shall not apply if the declared assets are not brought to Türkiye or transferred to the relevant accounts within the prescribed period, if domestic assets are not deposited with banks or intermediary institutions within the prescribed period, if the accrued taxes are not paid on time, if the undertakings given are not complied with, or if the other conditions set out in the article are not fulfilled. No correction can be made to declarations after the expiry of the declaration period. This amendment entered into force on the date of its publication in the Official Gazette.

Amendments to the Law No. 5746 on the Support of Research, Development and Design Activities

• The amendment to the R&D Law provides that the provisions of the Turkish Commercial Code relating to conditional capital increases shall not apply to conditional capital increases to be made, on the basis of convertible debt agreements, by non-public companies holding the technopreneurship badge issued by the Ministry of Industry and Technology. The procedures and principles relating to conditional capital increases of companies falling within this scope shall be determined by the Ministry of Industry and Technology after obtaining the opinion of the Ministry of Trade. This regulation is particularly significant because it establishes a special capital increase regime for convertible debt agreements used in the investment processes of technopreneurship companies.

In addition, under the same Law, it has been regulated that companies established and operated by entrepreneurs who have qualified as incubation entrepreneurs under the Technology Development Zones Law No. 4691, in accordance with the digital company definition to be determined by the Ministry of Industry and Technology, shall be exempt for up to three years from the date of establishment from the fees and dues defined in Article 24 of the Union of Chambers and Commodity Exchanges of Türkiye and Chambers and Commodity Exchanges Law No. 5174. This regulation constitutes an incentive aimed at reducing the financial burdens of early-stage technology ventures during their establishment and operational periods. This amendment entered into force on the date of publication in the Official Gazette.

Amendments to the Istanbul Financial Center Law No. 7412

• The amendment to the IFCL replaces the phrase “financial institutions having obtained a participant certificate” in Article 6 with “participants.” Through this amendment, the scope of the relevant exemption has been broadened from being limited solely to financial institutions to encompassing Istanbul Finance Center participants generally. In addition, it has been stipulated that the qualified service personnel wage exemption set out in subparagraph 20 of the first paragraph of Article 23 of the ITL shall not additionally apply to personnel of qualified service centres who benefit from this exemption. This provision is intended to prevent the application of a duplicative income tax exemption in respect of the same personnel.
• The amendment to provisional Article 1 of the IFCL also extends certain transition periods. In this context, the reference to the year 2031 has been replaced with 2047; and the five-year period has been redefined as twenty years. This regulation implies a significant extension of the incentive utilization period for participants operating or planning to operate in the Istanbul Financial Center. This amendment entered into force on the date of its publication in the Official Gazette.

In conclusion, the regulations introduced by Law No. 7582 may have significant implications, particularly for taxpayers with public debts, technopreneurship companies and their employees, individuals settling in Türkiye, foreign-capital group companies, companies planning to establish regional or intra-group service centres in Türkiye, Istanbul Finance Center participants, corporations engaged in manufacturing and agricultural production activities, real persons and legal entities holding assets abroad, and technology ventures. Accordingly, it would be beneficial to conduct further assessment in light of companies’ fields of activity, existing organizational structures, foreign-connected revenues, conditions for benefiting from incentives, share-based benefits provided to employees, and tax planning considerations.