Law No. 7582, published in the Official Gazette No. 33270 on 4 June 2026
Türkiye has enacted Law No. 7582, introducing significant amendments to its tax and foreign investment framework. The law targets four priority areas: attracting high net worth individuals relocating to Türkiye, establishing a new "qualified service centre" regime under foreign investment legislation, broadening corporate tax relief for cross-border trade and service activities, and offering a voluntary asset declaration mechanism. This article sets out the practical implications for businesses and individuals.
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1. Twenty-Year Income Tax Exemption for New Residents
The law adds a new Repeated Article 20/D to the Income Tax Law (Law No. 193), creating a substantial incentive for individuals relocating to Türkiye.
Scope: Individuals who become Turkish tax residents are exempt from income tax on income and revenue earned outside Türkiye for twenty years, provided they had no Turkish residence and no Turkish tax liability in the three calendar years preceding their establishment of residence.
Key features:
- Prior Turkish tax liability arising from real estate income, securities income, or capital gains does not disqualify the individual.
- No annual return is filed for the exempt foreign income. Where a return is filed for other income, the exempt income is excluded.
- Costs and expenses relating to the exempt income are disregarded when calculating taxable income.
- Foreign taxes paid on the exempt income cannot be credited against Turkish income tax.
- If the conditions are later found not to have been met, the unassessed tax is treated as tax loss.
The Ministry of Treasury and Finance will determine the application procedures. Under the transitional provision, this regime applies to individuals deemed resident from 1 January 2026 and takes effect on the date of publication.
Inheritance tax interaction: A new paragraph in the Inheritance and Transfer Tax Law (Law No. 7338) sets the tax rate at 1% for transfers by inheritance occurring within the exemption period for beneficiaries of the Repeated Article 20/D exemption.
2. The New Qualified Service Centre Regime
The law introduces a new Additional Article 1 to the Foreign Direct Investment Law (Law No. 4875), defining a "qualified service centre."
Definition: A qualified service centre is a capital company that:
- operates actively in at least three different countries,
- provides services to a related company or group of companies,
- carries out the activities listed below, and
- derives at least 80% of its annual revenue from related companies or groups abroad.
Eligible activities fall into two groups:
- Group (a): financial advisory, strategic management consulting, risk management, cash and liquidity management, funding and borrowing transactions, investment and capital structure planning, budgeting, financial reporting and analysis, international accounting and compliance, audit, digital transformation and technology consulting, investment and data analysis, legal advisory, promotion, brand management, human resources, training, and related coordination and management services.
- Group (b): coordination and management services relating to sales, after-sales support, technical support, research and development, outsourcing, testing of newly developed products, and laboratory services.
A practical restriction applies to legal advisory: advice on domestic activities or Turkish law may only be obtained from a lawyer or lawyer partnership authorised under the Attorneys Law (Law No. 1136). Employees who directly perform the listed services, excluding support staff, qualify as "qualified service personnel."
The Ministry of Industry and Technology will set the procedures after consulting the Ministry of Treasury and Finance and the Ministry of Trade.
3. Payroll Tax Relief for Qualified Service Personnel
A new subparagraph (20) is added to Article 23 of the Income Tax Law. Wages of qualified service personnel are exempt from income tax up to three times the gross minimum wage. The threshold rises to five times the gross minimum wage for qualified service centres operating in approved industrial zones (based on the zone's foreign investment density) or in the Istanbul Finance Centre with a participant certificate.
The President is authorised to set both multipliers, jointly or separately, down to one, or to increase them up to twofold.
Personnel benefiting from this exemption cannot also use the Istanbul Finance Centre wage exemption under Law No. 7412, following a corresponding amendment to that law.
4. Corporate Tax Relief for Cross-Border Trade and Services
The law amends Article 10 of the Corporate Tax Law (Law No. 5520).
Cross-border trade (revised subparagraph (i)): 95% of income from selling goods purchased abroad without bringing them into Türkiye, or from intermediating sales conducted abroad, is deductible. The rate rises to 100% for qualifying entities in approved industrial zones or the Istanbul Finance Centre. Conditions: the income must be transferred to Türkiye by the corporate tax return deadline, and for intermediation, both buyer and seller must be outside Türkiye.
Qualified service centres (new subparagraph (j)): 95% of foreign income derived by qualified service centres exclusively from these activities is deductible, rising to 100% for those in approved industrial zones or the Istanbul Finance Centre. The income must be transferred to Türkiye by the return deadline. The deduction applies for twenty accounting periods from the period in which the centre begins operations.
The President may adjust these rates within the limits set in each subparagraph.
Effective date: These provisions apply to returns due from 1 July 2026 and to corporate income for the tax period beginning 1 January 2026.
5. Reduced Corporate Tax Rate for Producers
Article 32 of the Corporate Tax Law is amended to apply a 12.5% corporate tax rate to income derived exclusively from production by companies holding an industrial registry certificate and actually engaged in production, and to income from agricultural production. Companies using this reduced rate cannot also apply the separate reduction under the seventh paragraph. This applies to income earned in 2027 and subsequent periods.
6. Voluntary Asset Declaration (Temporary Article 19)
The law introduces a voluntary declaration regime for previously undeclared assets, available until 31 July 2027.
Foreign assets: Individuals and legal entities may declare money, gold, foreign currency, securities, and other capital market instruments held abroad to banks or intermediary institutions. Declared assets must be transferred to Turkish accounts within two months, or, if brought physically, deposited and documented through customs declaration.
Domestic assets: Taxpayers may declare such assets held in Türkiye but not recorded in their statutory books, with proof by deposit into a bank or intermediary institution.
Bookkeeping treatment: Taxpayers record declared assets in their statutory books. Balance sheet taxpayers open a special fund account on the liabilities side. This fund cannot be withdrawn for two years, may only be used for capital increase, and is not taxed on liquidation.
Tax rate: Banks and intermediary institutions collect a base 5% tax on the declared value. Reduced rates apply where the asset is committed to time deposits, government debt instruments or lease certificates issued under Law No. 4749, or venture capital investment funds:
- 5 years: 0%
- 4 years: 1%
- 3 years: 2%
- 2 years: 3%
- 1 year: 4%
Declarations made from 1 January 2027 to 31 July 2027 carry a half-point increase. If the deadline is extended, declarations after the original date carry a further half-point increase (one point total).
Protection from audit: Declared amounts are not subject to tax inspection or assessment, subject to detailed offset rules where audits begin for other reasons. The tax paid cannot be deducted, credited, or refunded. Failure to meet the conditions, transfer the assets, or pay the assessed tax on time forfeits the protection, and unassessed tax is collected with delay interest (without tax loss penalty).
The President may extend the 31 July 2027 deadline by up to one year in successive periods of no more than six months.
7. Support for Start-ups and R&D Ventures
Two paragraphs are added to Article 3 of Law No. 5746 (R&D and Design Support):
- Convertible debt financing: For privately held companies holding a "technology start-up badge" issued by the Ministry of Industry and Technology, the conditional capital increase provisions of the Turkish Commercial Code (Law No. 6102) do not apply to conditional capital increases based on convertible debt agreements. The Ministry will set the procedures after consulting the Ministry of Trade.
- Fee exemption for digital companies: Companies established by qualified incubation entrepreneurs under Law No. 4691, meeting the Ministry's "digital company" definition, are exempt from chamber fees and dues under Law No. 5174 for up to three years from incorporation.
8. Istanbul Finance Centre Extension
Amendments to Law No. 7412 extend the relevant tax incentive period from 2031 to 2047 and increase a qualifying period from five to twenty years.
9. Payment Plan Threshold Increase
The law amends Article 48 of the Law on Collection Procedure of Public Receivables (Law No. 6183), extending the maximum instalment period from 36 to 72 months and raising the relevant threshold from "fifty thousand New Turkish Lira" to "one million Turkish Lira."
Practical Assessment
Law No. 7582 signals a coordinated effort to position Türkiye as a regional base for multinational service and treasury functions, to attract relocating individuals through a long exemption period, and to encourage the repatriation of offshore assets. The qualified service centre regime, combined with the corporate and payroll tax relief, is the most commercially significant element for groups considering a Turkish hub. Businesses should note the strict conditions attached to each incentive, in particular the residency tests, the revenue source threshold for service centres, the transfer-to-Türkiye requirements, and the forfeiture rules under the asset declaration regime.
Secondary legislation from the relevant ministries will determine the operational details. Companies and individuals evaluating these incentives should monitor those implementing regulations before structuring transactions.
Frequently Asked Questions (FAQ)
What is Law No. 7582?
Law No. 7582 amends several Turkish tax and investment laws. It was published in the Official Gazette No. 33270 on 4 June 2026. The main changes cover income tax exemptions for new residents, a new qualified service centre regime, corporate tax relief for cross-border trade and services, a reduced rate for producers, and a voluntary asset declaration mechanism.
When does the law take effect?
Most provisions take effect on the publication date, 4 June 2026. The new resident exemption applies to individuals deemed resident from 1 January 2026. The corporate tax changes for cross-border trade and services apply to returns due from 1 July 2026 and to income from the tax period beginning 1 January 2026. The reduced 12.5% producer rate applies from the 2027 tax period.
Who can use the twenty-year foreign income exemption?
Individuals who become Turkish tax residents, provided they had no Turkish residence and no Turkish tax liability in the three calendar years before establishing residence.
What income does the exemption cover?
Income and revenue earned outside Türkiye. The exemption runs for twenty years.
Does prior Turkish tax liability disqualify me?
Not if it arose only from Turkish real estate income, securities income, or capital gains. Other prior Turkish tax liability would breach the three-year condition.
Do I have to file a return for the exempt foreign income?
No. If you file a return for other income, the exempt foreign income is excluded from it.
Can I credit foreign taxes paid on that income against Turkish tax?
No. Foreign taxes paid on the exempt income cannot be credited against Turkish income tax. Related costs and expenses are also disregarded.
What happens if the conditions are later found not to have been met?
The unassessed tax is treated as tax loss and will be pursued.
Is there an inheritance tax benefit?
Yes. Transfers by inheritance occurring within the exemption period are taxed at 1% for beneficiaries of this exemption.
What is a qualified service centre?
A capital company that operates in at least three different countries, serves a related company or group, carries out the listed activities, and derives at least 80% of annual revenue from related companies or groups abroad.
What activities qualify?
Two groups: (a) financial, advisory, management, accounting, audit, technology, legal, brand, and human resources services with related coordination and management; and (b) coordination and management of sales, after-sales, technical support, R&D, outsourcing, product testing, and laboratory services.
Are there limits on legal advisory services?
Yes. Advice on domestic activities or Turkish law may only be obtained from a lawyer or lawyer partnership authorised under the Attorneys Law (Law No. 1136).
Who counts as qualified service personnel?
Employees who directly perform the listed services, excluding support staff.
Who sets the detailed rules?
The Ministry of Industry and Technology, after consulting the Ministry of Treasury and Finance and the Ministry of Trade.
How much of the salary is exempt?
Wages of qualified service personnel are exempt up to three times the gross minimum wage. The threshold rises to five times the gross minimum wage in approved industrial zones or the Istanbul Finance Centre with a participant certificate.
Can personnel combine this with the Istanbul Finance Centre exemption?
No. Personnel using this exemption cannot also use the Istanbul Finance Centre wage exemption under Law No. 7412.
What relief applies to cross-border trade?
95% of income from selling goods bought abroad without bringing them into Türkiye, or from intermediating sales conducted abroad, is deductible. The rate is 100% in approved industrial zones or the Istanbul Finance Centre.
What are the conditions for the trade relief?
The income must be transferred to Türkiye by the corporate tax return deadline. For intermediation, both buyer and seller must be outside Türkiye.
What relief applies to qualified service centres?
95% of foreign income from these activities is deductible, rising to 100% in approved industrial zones or the Istanbul Finance Centre. The relief applies for twenty accounting periods from the period the centre begins operations, with transfer to Türkiye required by the return deadline.
What is the reduced rate for producers?
A 12.5% corporate tax rate applies to income earned exclusively from production by companies holding an industrial registry certificate and actually engaged in production, and to agricultural production income. It applies from the 2027 tax period and cannot be combined with the separate reduction under Article 32, seventh paragraph.
What can be declared?
Money, gold, foreign currency, securities, and other capital market instruments held abroad, or held in Türkiye but not recorded in statutory books.
What is the deadline?
31 July 2027. The President may extend it by up to one year in successive periods of no more than six months.
How must foreign assets be handled after declaration?
They must be transferred to Turkish accounts within two months, or, if brought physically, deposited and documented through a customs declaration.
What tax applies?
A base rate of 5% on the declared value. Reduced rates apply for commitments to hold the asset in qualifying instruments: 0% for five years, 1% for four years, 2% for three years, 3% for two years, and 4% for one year.
Are there rate increases?
Yes. Declarations from 1 January 2027 to 31 July 2027 carry a half-point increase. If the deadline is extended, declarations after the original date carry a further half-point increase.
Are declared assets protected from audit?
Declared amounts are not subject to tax inspection or assessment, subject to detailed offset rules where an audit begins for other reasons. Tax paid cannot be deducted, credited, or refunded.
What if the conditions are not met?
The protection is forfeited. Unassessed tax is collected with delay interest, without tax loss penalty.
Can a declaration be corrected after the deadline?
No. No correction is allowed after the declaration period ends.
What changes for technology start-ups?
Privately held companies holding a technology start-up badge can carry out conditional capital increases based on convertible debt agreements without applying the Turkish Commercial Code conditional capital increase provisions.
Is there a fee exemption for new digital companies?
Yes. Companies established by qualified incubation entrepreneurs under Law No. 4691 that meet the Ministry's digital company definition are exempt from chamber fees and dues for up to three years from incorporation.
What changed for the Istanbul Finance Centre?
The relevant incentive period was extended from 2031 to 2047, and a qualifying period was increased from five to twenty years.
What changed for public receivable payment plans?
The maximum instalment period was extended from 36 to 72 months, and the relevant threshold was raised from fifty thousand New Turkish Lira to one million Turkish Lira.
