Law No. 7582 on the Amendment of Certain Laws was adopted by the General Assembly of the Grand National Assembly of Türkiye on 21 May 2026. The Law is expected to be implemented in accordance with its provisions on entry into force following its publication in the Official Gazette.

Law No. 7582 is not merely a limited amendment concerning certain tax rates. The regulation constitutes a multifaceted legislative amendment that may directly affect Türkiye’s investment environment, international capital movements, the production economy, the Istanbul Finance Center strategy, the technology entrepreneurship ecosystem, intra group service center structures and the residence regime for high net worth individuals.

The Law introduces simultaneous amendments to several fundamental laws, including the Law No. 6183 on the Procedure for the Collection of Public Receivables, the Income Tax Law No. 193, the Corporate Tax Law No. 5520, the Inheritance and Transfer Tax Law No. 7338, the Foreign Direct Investment Law No. 4875, the Law No. 5746 on the Support of Research, Development and Design Activities and the Istanbul Finance Center Law No. 7412.

In this respect, Law No. 7582 has a broad scope of application, ranging from the collection of public receivables to corporate tax rates, from the asset repatriation regime to the income tax exemption for new residents, and from qualified service centers to incentives for the Istanbul Finance Center. The regulation gives rise to consequences that should be carefully assessed, particularly for companies, foreign investors, financial institutions, manufacturing enterprises, technology startups, family offices and multinational groups considering the establishment of a regional center in Türkiye.

Key Amendments during the Legislative Process

One of the most notable amendments during the legislative process of the Law concerns the redesign of the scope of the corporate tax reduction. In the initial version of the bill, it was envisaged that a corporate tax rate of 9 percent would apply to the income derived by manufacturing exporter corporations from the goods they exported, while a rate of 14 percent would apply to the export income of other exporter corporations.

However, this structure was abandoned at the stage of the Planning and Budget Committee. The reduced rate was redirected, without being subject to an export condition, to the income derived exclusively from production activities by corporations holding an industrial registry certificate and actually engaged in production activities, as well as to income derived from agricultural production activities. In this context, the corporate tax rate for such income was set at 12.5 percent.

At the General Assembly stage, certain important additions expanding the scope of the package were introduced. Industrial zones were brought to the same level as the Istanbul Finance Center in respect of certain incentives, venture capital investment funds were added to the investment instruments eligible for the reduced tax rate under the asset repatriation regime, and the undertakings to be submitted in relation to the holding of assets were exempted from stamp duty.

In addition, it was regulated that qualified service centers may provide legal consultancy services relating to domestic activities or Turkish law only by procuring such services from attorneys or attorney partnerships authorized to provide services under the Attorneyship Law No. 1136.

This final amendment is also significant in terms of the nature of legal services and professional boundaries. Although the qualified service center regime is designed in a manner that may cover activities such as intra group legal coordination and international contract management of multinational companies, a boundary compatible with the Attorneyship Law has been drawn in respect of legal consultancy relating to Turkish law or activities in Türkiye. Thus, the statutory framework of the legal profession has been preserved in respect of legal consultancy activities, while a balance has been established between the multinational service center model and the regime of professional representation and consultancy under Turkish law.

Deferral Period for Public Receivables Extended

The amendment introduced by the Law to Law No. 6183 redesigns the period and amount regime applicable to the deferral of public receivables. The deferral period is increased from 36 months to 72 months, while the maximum amount of debt that may be deferred without collateral is raised to TRY 1,000,000.

This amendment creates an important payment facility, particularly for taxpayers under cash flow pressure, by allowing public debts to be spread over a longer term.

The regulation in question does not constitute a tax amnesty or the discharge of debt in the classical sense. However, for businesses experiencing payment difficulties, it introduces an expansion of the deferral mechanism that may produce practical results in terms of restructuring public debts and spreading the pressure of collection over time.

Especially in periods of high interest rates, difficulty in accessing financing and increased working capital needs, the possibility of deferral extending up to 72 months may become an instrument that companies should take into consideration in terms of liquidity management.

Twenty Year Exemption for Foreign Income and Revenues of New Residents

One of the most notable regulations introduced by the Law is the twenty year income tax exemption for foreign income and revenues of individuals who settle in Türkiye.

Under repeated Article 20/D added to the Income Tax Law, the income and revenues derived outside Türkiye by individuals deemed to be resident in Türkiye are exempt from income tax for a period of twenty years, provided that they did not have a residence or tax liability in Türkiye during the last three calendar years preceding the year in which they are deemed to have become resident in Türkiye.

This exemption demonstrates Türkiye’s intention to develop a new residence regime aimed at attracting high income individuals, international investors, family offices, entrepreneurs and holders of mobile capital.

No annual income tax return will be filed for income falling within the scope of the exemption. Where an income tax return must be filed due to other income, the income and revenues within the scope of the exemption will not be included in the return. However, expenses and costs connected with income falling within the scope of the exemption may not be taken into account in determining taxable income, and taxes paid abroad due to such income may not be credited against income tax calculated in Türkiye.

An important complementary element of the regulation concerns inheritance and transfer tax. If the person benefiting from the exemption passes away during the twenty year exemption period, a fixed inheritance and transfer tax rate of 1 percent will apply to the assets transferred by inheritance.

This provision is capable of significantly affecting not only the annual income tax burden, but also the tax burden on the intergenerational transfer of wealth, particularly for high net worth individuals and family wealth structures considering relocation to Türkiye.

Qualified Service Center Regime

With the regulation added to the Foreign Direct Investment Law, the concept of a “qualified service center” is introduced into the legislation. A qualified service center is defined as a capital company established to provide services to affiliated companies or a group of companies actively operating in at least three different countries, and deriving at least 80 percent of its annual revenue from foreign affiliated companies or the relevant group of companies.

This regime aims to encourage multinational corporate groups to conduct their regional management, coordination, support and expertise functions through Türkiye.

The areas of activity of qualified service centers have been defined broadly. Intra group support and coordination functions such as financial consultancy, treasury and funding, reporting, audit, risk management, cash and liquidity management, international accounting and compliance, strategic management consultancy, digital transformation, technology consultancy, investment and data analysis, brand management, human resources, training, after sales support, technical support, research and development, outsourcing, product testing and laboratory services may be assessed within this scope.

The qualified service center regime is supported by three main tax advantages.

First, 95 percent of the income derived exclusively from abroad within the scope of qualified service center activities may be deducted from corporate income. This rate will be applied as 100 percent for qualified service centers operating in the Istanbul Finance Center and for corporations operating in certain industrial zones deemed appropriate by the President.

In order to benefit from this deduction, the income must be transferred to Türkiye by the date on which the corporate tax return is required to be filed. The deduction will apply for twenty accounting periods starting from the accounting period in which the qualified service center commences its activities.

Second, the portion of the wages of qualified service personnel employed in qualified service centers that does not exceed three times the gross minimum wage is exempt from income tax. For qualified service centers operating in the Istanbul Finance Center and for corporations operating in industrial zones deemed appropriate by the President, this limit will be applied as five times the gross minimum wage.

Third, it is envisaged that the qualified service center income deduction may be deducted from the domestic minimum corporate tax base. This is a critical complementary regulation aimed at preventing the new incentive from becoming ineffective within the calculation of minimum corporate tax.

Deduction for Transit Trade and Foreign Intermediation Income

As a result of the amendment made by the Law to Article 10 of the Corporate Tax Law, the scope of the corporate tax deduction applicable to income derived from transit trade and foreign intermediation activities is significantly expanded.

Accordingly, 95 percent of the income derived from the sale abroad of goods purchased from abroad without being brought into Türkiye, or from intermediation in the purchase and sale of goods occurring abroad, may be deducted from the corporate tax base.

For corporations operating in the Istanbul Finance Center and for corporations operating in industrial zones established under the Industrial Zones Law No. 4737 and deemed appropriate by the President based on the concentration of foreign investment, this deduction rate will be applied as 100 percent.

Thus, compared to the previous regime, the transit trade incentive both expands geographically beyond the Istanbul Finance Center and becomes a stronger incentive in terms of rate.

In order to benefit from the deduction, the income must be transferred to Türkiye by the date on which the corporate tax return for the relevant accounting period is required to be filed. In respect of intermediation activities, it will also be required that neither the seller nor the buyer of the goods is located in Türkiye.

In this respect, the regulation aims to make Türkiye a more attractive location for international trade, supply chain coordination and regional trade center structures where the goods do not physically enter the country.

Corporate Tax Rate of 12.5 Percent for Manufacturing and Agricultural Production Activities

The most important regulation of the Law concerning the production economy is the determination of the corporate tax rate as 12.5 percent for income derived exclusively from production activities by corporations holding an industrial registry certificate and actually engaged in production activities, and for income derived exclusively from agricultural production activities by corporations engaged in such activities.

This regulation differs from the export oriented corporate tax reduction model at the proposal stage. In the final text of the Law, the export condition was removed and the reduced rate was structured on the basis of production activity and agricultural production activity.

Therefore, not only manufacturers engaged in export activities, but also industrial registry certified producers manufacturing for the domestic market may benefit from the 12.5 percent rate if they meet the relevant conditions. The inclusion of corporations engaged in agricultural production activities also demonstrates that the regulation is not limited solely to industrial production.

However, it will not be possible to apply both the 12.5 percent rate and the 5 point deduction under the Corporate Tax Law for export income in respect of the same income. The Law makes a clear distinction in this regard and provides that the additional 5 point exporter deduction may not be applied to income benefiting from the reduced rate.

This amendment will create a new tax planning agenda for companies, particularly in relation to the planning of production investments, the separation of intra group production and trading activities, the accounting tracking of export income and production income, and the separation of income arising from different activities.

In practice, the issues of how the reduced rate will be applied to different income items, how income other than production activity will be separated and how income will be determined in companies with mixed activity structures will gain importance.

New Deductions in the Domestic Minimum Corporate Tax Base

The Law also amends Article 32/C of the Corporate Tax Law concerning domestic minimum corporate tax. Accordingly, the transit trade income deduction, the qualified service center income deduction and the financial service export income deduction under the Istanbul Finance Center Law are included among the deductions that may be deducted from the domestic minimum corporate tax base.

Although this regulation is technical in nature, it is of great importance for the effectiveness of the package. Otherwise, the newly introduced income deductions could have become ineffective in practice due to minimum corporate tax, reducing the real economic value of the incentives for investors.

By allowing these deductions to be taken into account in the minimum corporate tax base, the Law strengthens the applicability of the transit trade, qualified service center and Istanbul Finance Center incentives.

New Asset Repatriation Regime

The Law introduces a new asset repatriation regime under provisional Article 19 added to the Corporate Tax Law.

Money, gold, foreign currency, securities and other capital market instruments located abroad, as well as assets of the same nature located in Türkiye but not recorded in statutory books, may be notified to banks or intermediary institutions in Türkiye until 31 July 2027.

Assets located abroad must be brought to Türkiye or deposited into bank or intermediary institution accounts in Türkiye within two months from the date of notification.

As a rule, it is envisaged that an upfront tax of 5 percent will be collected in relation to the assets notified under the asset repatriation regime. However, if an undertaking is given to hold the notified assets in Türkiye for certain periods, the tax rate decreases gradually.

Time deposit accounts, government domestic debt securities, lease certificates and participation shares of venture capital investment funds added at the General Assembly stage are among the investment instruments that may be taken into account within this scope.

Where there is no undertaking to hold the assets, the rate will be applied as 5 percent, while the rates will gradually decrease depending on the undertaking period. Accordingly, a rate of 4 percent may apply if an undertaking is given to hold the assets for at least one year, 3 percent if an undertaking is given for at least two years, 2 percent if an undertaking is given for at least three years, 1 percent if an undertaking is given for at least four years and 0 percent if an undertaking is given for at least five years.

For notifications to be made from 1 January 2027 until 31 July 2027, these rates will be increased by half a point. The President is authorized to extend the notification period by up to one year, and an additional increase in the rates is envisaged in the event of such extension.

The regulation also provides that, if the conditions are met, no tax audit or tax assessment will be conducted in respect of the amounts corresponding to the notified assets.

In addition, the fact that no stamp duty will be collected on undertakings to be submitted in relation to the holding of assets constitutes an important complementary regulation that reduces transaction costs, particularly for high value notifications.

Share Certificate Exemption and Convertible Debt Regime in Technology Startups

The Law introduces important innovations for technology startups in terms of both employee incentives and financing models.

With the amendment made to Article 17 of the Income Tax Law, the upper limit of the income tax exemption for share certificates granted free of charge or at a discount to employees by employers qualifying as technology startup companies is increased from one times to two times the employee’s annual gross wage.

The clawback mechanism linked to the holding period of the share certificates is also softened in favor of employees. If the share certificates are disposed of within two years from the date of acquisition, the entirety of the exempted tax will be collected from the employer together with default interest. If they are disposed of between three and four years, 75 percent of the exempted tax will be collected, and if they are disposed of between five and six years, 25 percent of the exempted tax will be collected.

For share certificates held for more than six years, the clawback mechanism will not apply. Considering that the previous regime prescribed a twelve year period for full exemption, this amendment makes it more realistic for technology startup employees to benefit from share based incentives.

Another important innovation introduced by the Law for the technology entrepreneurship ecosystem is the special regime concerning convertible debt agreements.

With the amendment made to Law No. 5746, it is regulated that the provisions of the Turkish Commercial Code on conditional capital increase will not apply to conditional capital increases to be made under convertible debt agreements by non public companies holding a technology startup badge granted by the Ministry of Industry and Technology.

The procedures and principles in this area are envisaged to be determined by the Ministry of Industry and Technology after obtaining the opinion of the Ministry of Trade.

This regulation has the potential to create a more flexible legal basis in Türkiye for convertible debt, SAFE like instruments and pre investment round bridge financing models frequently used in startup financing.

In addition, the exemption granted to digital companies from chamber dues during the incorporation and operation periods stands out as a complementary regulation aimed at reducing early stage costs for technology startups.

Expansion and Extension of Istanbul Finance Center Incentives

The Law also strengthens the Istanbul Finance Center regime. Although the main deduction rate under the Istanbul Finance Center Law No. 7412 is 75 percent, the period during which the rate is applied as 100 percent for income derived from financial service export activities is extended until 31 December 2047.

It is also expressly regulated that this deduction may be deducted from the tax base in the calculation of domestic minimum corporate tax.

The exemption period for financial activity fees that must be collected under the Fees Law from the headquarters and branches of financial institutions holding a participant certificate and located in the Istanbul Finance Center is also increased from five years to twenty years.

In addition, the scope of the income tax exemption for personnel working in the Istanbul Finance Center is expanded. The incentive previously envisaged for certain financial institutions is restructured in a manner that will provide a broader area of application in favor of Istanbul Finance Center participants.

These amendments concerning the Istanbul Finance Center indicate that the Istanbul Finance Center is intended to be positioned not merely as a location based incentive for financial institutions, but as a more comprehensive international business and finance center model connected with qualified service centers, financial service exports, transit trade and the employment of highly qualified personnel.

Position of Industrial Zones in the Incentive System

With the amendments made at the General Assembly stage, certain industrial zones deemed appropriate by the President have been brought to the same level as the Istanbul Finance Center in respect of certain incentives.

In this context, the qualified service center income deduction and the transit trade income deduction may be applied at a rate of 100 percent for corporations operating in industrial zones deemed appropriate. In addition, for the wage exemption of qualified service personnel, the limit of five times the gross minimum wage will apply instead of three times the gross minimum wage.

This regulation reflects an approach that does not limit the geographical impact of the package solely to Istanbul. However, it cannot be said that all industrial zones will automatically benefit from these advantages.

The system established by the Law envisages the application of more advantageous rates for industrial zones deemed appropriate within the framework of criteria such as the concentration of foreign investment. Therefore, when investment planning is carried out, it should be separately assessed whether the relevant industrial zone has been included within this scope.

Entry into Force and Implementation Calendar

Many provisions of the Law will enter into force on the date of its publication in the Official Gazette. However, special application dates have been envisaged for certain regulations.

The regulations concerning the qualified service center income deduction, the transit trade income deduction and the domestic minimum corporate tax base are envisaged to apply to corporate income for taxation periods beginning as of 1 January 2026, starting with the tax returns required to be filed as of 1 July 2026.

The exemption for foreign income and revenues of new residents will apply to individuals deemed to have become resident in Türkiye as of 1 January 2026.

The corporate tax rate of 12.5 percent for income derived from manufacturing and agricultural production activities will enter into force to apply to income earned in the 2027 and following taxation periods.

For asset repatriation notifications, the deadline has been set as 31 July 2027, and the President has been authorized to extend this period by up to one year.

Assessment

Law No. 7582 is one of the most comprehensive and multidimensional regulations introduced in Türkiye’s tax and investment legislation in recent years.

When the general architecture of the Law is examined, three main policy axes come to the fore.

First, through the twenty year foreign income exemption for new residents and the 1 percent inheritance tax regulation, Türkiye aims to offer a more competitive residence regime for internationally mobile capital and high net worth individuals.

Second, through the qualified service center regime, transit trade incentives, Istanbul Finance Center advantages and provisions concerning industrial zones, it is intended to make Türkiye a stronger center for regional management, finance, supply chain and high value added service activities.

Third, through the 12.5 percent corporate tax rate for manufacturing and agricultural production income, the share certificate exemption in technology startups and the convertible debt regime, a more competitive tax and financing basis is being established for the production and technology ecosystem.

From the perspective of companies, these regulations should not be assessed merely as tax rate or exemption headings. They give rise to the need for a comprehensive legal and financial analysis in respect of group structures, the transfer of foreign income to Türkiye, service center models, the separation of production and export income, the granting of share based benefits to employees, startup financing agreements, asset notification decisions and location preferences concerning the Istanbul Finance Center or industrial zones.

For this reason, upon the entry into force of Law No. 7582, it is important that restructuring and compliance work suitable for the new period be initiated without delay, particularly for multinational corporate groups, manufacturing companies, exporters, technology startups, financial institutions, family offices, high net worth individuals and foreign investors considering the establishment of a regional center in Türkiye.

As Çetin Attorney Partnership, we assess the legal and tax implications that companies, investors and international business groups may face within the changing legislative framework from a holistic perspective, and provide strategic legal support in relation to corporate structuring, investment planning, compliance processes and the management of contractual risks.