06.06.2026/6

06.06.2026/6

Law No. 7582 Has Been Published, Introducing a New Asset Repatriation Scheme and a 12.5 Percentage Point Corporate Tax Reduction for Manufacturing Companies.

Law No. 7582 on Amendments to Certain Laws was published in the Official Gazette No. 33270 dated 4 June 2026.

The key amendments introduced by the aforementioned Law are summarized below.

1. Amendments Introduced to the Deferral Period and Collateral Threshold under Law No. 6183

The phrase “36” in the first paragraph of Article 48 of Law No. 6183 on the Procedure for the Collection of Public Receivables has been amended to “72”, while the phrase “fifty thousand New Turkish Lira” in the second paragraph has been replaced with “one million Turkish Lira.”

Article 48 of Law No. 6183 governs the procedures and principles regarding the deferral of public receivables. Pursuant to this amendment:

• The maximum deferral period has been extended from 36 months to 72 months.
• The threshold for deferral without the requirement to provide collateral has been increased from TRY 250,000 to TRY 1,000,000.

Accordingly, taxpayers will be granted the opportunity to settle their public liabilities over a significantly longer repayment period.

This amendment will enter into force on the date of publication of the Law.

2. Foreign-Sourced Exempt Income and Earnings Made Subject to Inheritance and Gift Tax at a 1% Rate

Article 2 of the Law introduces a new paragraph to Article 16 (“Tax Rates”) of the Inheritance and Gift Tax Law.

Under this amendment, individuals benefiting from the foreign-sourced income exemption provided under Provisional Article 20/D of the Income Tax Law (the details and conditions of which are explained under Section 4 below) will be subject to Inheritance and Gift Tax at a rate of 1% on assets acquired through inheritance during the exemption period (20 years).

Through this amendment, the tax incentives available to high-net-worth foreign individuals and persons with international connections who relocate to Türkiye have been further expanded.

This amendment will enter into force on the date of publication of the Law.

3. Amendments Introduced to the Exemption Cap and Holding Period Requirements for Shares Granted Free of Charge or at a Discount by Tech Start-Up Employers

Article 3 of the Law amends Article 17 of the Income Tax Law, titled “Wage Tax Exemption for Benefits Provided through the Grant of Shares to Employees.”

Under Article 17 of the Income Tax Law, shares granted free of charge or at a discount by employers qualifying as technology start-up companies (teknogirişim companies) to their employees, and treated as employment income, were exempt from income tax to the extent that the fair market value of such shares on the grant date did not exceed the employee’s annual gross salary for that year.

With the amendment:

• The exemption threshold has been increased from one annual gross salary to two times the employee’s annual gross salary.
• The holding periods applicable to the recapture of taxes not collected under the exemption regime, where the granted shares are disposed of before the required holding period, have been shortened.

This amendment will enter into force on the date of publication of the Law.

4. A 20-Year Income Tax Exemption Has Been Introduced for Foreign-Sourced Income and Earnings

Law No. 7582 introduces Provisional Article 20/D, titled “Tax Exemption for Foreign-Sourced Income and Earnings,” into the Income Tax Law. The new provision grants a temporary income tax exemption for certain foreign-sourced income and earnings of individuals who relocate to Türkiye.

Under the new regulation:

Foreign-sourced income and earnings derived by individuals deemed resident in Türkiye will be exempt from Turkish income tax for a period of 20 years, provided that such individuals did not have a domicile in Türkiye, and were not considered full taxpayers in Türkiye during the three calendar years preceding their relocation to Türkiye.

The existence of a prior tax liability in Türkiye arising from real estate income, investment income, or capital gains earned before qualifying under this provision will not prevent individuals from benefiting from the exemption.

The regulation further provides that:

• No tax return will be required to be filed for income covered by the exemption.
• If a tax return is filed due to other taxable income, the exempt foreign-sourced income and earnings will not be included in such return.
• Expenses attributable to exempt income and earnings will not be deductible.
• Foreign taxes paid on exempt income and earnings will not be creditable against Turkish tax liabilities.

This provision is primarily intended to encourage high-net-worth foreign investors and Turkish citizens residing abroad to relocate to Türkiye by offering a significant long-term tax incentive.

The amendment entered into force upon publication and will apply to individuals who become resident in Türkiye on or after 1 January 2026.

5. Income Tax Exemption for Qualified Service Personnel

Article 5 of the Law introduces subparagraph (20) to the first paragraph of Article 23 of the Income Tax Law No. 193, which regulates income tax exemptions applicable to employment income.

Accordingly, the salaries paid to qualified service personnel employed by qualified service centers operating within the scope of the Foreign Direct Investment Law No. 4875 will benefit from an income tax exemption.

Under the new provision:

• The portion of the employee’s salary not exceeding three times the gross minimum wage will be exempt from income tax. For qualified service centers operating in industry zones designated by the President and within the Istanbul Financial Center, the exemption will apply to the portion of the salary not exceeding five times the gross minimum wage.

This measure aims to enhance Türkiye’s attractiveness as a regional service hub and encourage the establishment of international service centers in the country.

The amendment will enter into force on the date of publication of the Law.

6. Definition of a Qualified Service Center

Article 6 of the Law introduces Additional Article 1, titled “Qualified Service Center,” into the Foreign Direct Investment Law No. 4875.

According to the new provision, companies that meet all of the following conditions will be classified as Qualified Service Centers:

• They operate actively in at least three different countries;
• They are established to provide services to related group companies, including management, finance, accounting, technology, human resources, legal coordination, and R&D coordination services;
• At least 80% of their service revenues are derived from related companies located outside Türkiye.

Employees who directly provide services within these centers are defined as Qualified Service Personnel for the purposes of the relevant tax incentives.

This amendment will enter into force on the date of publication of the Law.

7. Corporate Tax Deduction for Foreign Trade and Service Income

Article 7 of the Law introduces amendments and additions to Article 10 of the Corporate Tax Law No. 5520.

a) Income Derived from Transit Trade Activities

Subparagraph (i) of Article 10 of the Corporate Tax Law has been amended as follows:

95% of the income derived from:

• the sale abroad of goods purchased from abroad without being brought into Türkiye, or
• intermediary activities relating to the purchase and sale of goods abroad,

may be deducted from the corporate tax base.

For companies operating in Presidentially designated industry zones and in the Istanbul Financial Center with a valid participant certificate, the deduction rate will be 100%.

In order to benefit from this deduction:

• The relevant income must be transferred to Türkiye by the deadline for filing the corporate income tax return for the respective fiscal year; and
• In intermediary transactions, neither the seller nor the purchaser of the goods may be located in Türkiye.

b) Income Derived by Qualified Service Centers

A new subparagraph (j) has been added to Article 10 of the Corporate Tax Law.

Accordingly, 95% of the income earned abroad by Qualified Service Centers exclusively from their qualified service activities may be deducted from the corporate tax base.

For companies operating in Presidentially designated industry zones and in the Istanbul Financial Center with a valid participant certificate, the deduction rate will be 100%.

This deduction will apply for twenty fiscal periods, commencing from the fiscal period in which the Qualified Service Center begins its operations, provided that the relevant income is transferred to Türkiye by the deadline for filing the annual corporate income tax return for the period in which the income is earned.

Effective Date

The amendment entered into force upon publication and will apply to:

• Corporate tax returns required to be filed on or after 1 July 2026; and
• Corporate income derived in tax periods commencing on or after 1 January 2026 (or accounting periods commencing on or after that date for taxpayers with a special fiscal year).

8. A 12.5% Corporate Tax Rate Will Apply to Income Derived from Manufacturing Activities and Agricultural Production

Article 8 of the Law amends paragraph 8 of Article 32 of the Corporate Tax Law.

Under the current rules, income derived from manufacturing activities is subject to a reduced corporate tax rate through a 1 percentage point tax reduction, resulting in an effective tax rate of 24%. The amendment significantly increases the tax benefit and extends its scope to include income derived from agricultural production activities.

Accordingly, the following income will be subject to a 12.5% corporate tax rate:

• Income derived from manufacturing activities carried out by enterprises holding a valid Industrial Registration Certificate (Sanayi Sicil Belgesi); and
• Income derived exclusively from agricultural production activities by enterprises engaged in agricultural production.

For income benefiting from this reduced tax rate, the additional 5 percentage point corporate tax reduction applicable to export income will not be available.

Effective Date

This amendment entered into force upon publication and will apply to:

• Income earned in the 2027 and subsequent tax periods; and
• For corporations subject to a special accounting period, income earned in the special accounting period commencing in the 2027 calendar year and subsequent tax periods.

9. Transit Trade, Qualified Service Center, and Istanbul Financial Center Deductions Excluded from the Domestic Minimum Corporate Tax Base

Article 9 of the Law amends Article 32/C of the Corporate Tax Law.

Under the amendment, the following deductions have been added to the list of items that may be deducted from corporate income when calculating the Domestic Minimum Corporate Tax:

• The Transit Trade Income Deduction;
• The Qualified Service Center Income Deduction; and
• Certain income deductions available under the Istanbul Financial Center regime.

As a result, these deductions will reduce the corporate income base used for the calculation of the Domestic Minimum Corporate Tax.

Effective Date

The amendment entered into force upon publication and will apply to:

• Corporate tax returns required to be filed on or after 1 July 2026; and
• Corporate income derived in tax periods commencing on or after 1 January 2026 (or accounting periods commencing on or after that date for taxpayers with a special fiscal year).

10. New Asset Repatriation Regime Introduced: Preferential Taxation and Protection Against Tax Audits and Assessments for Cash, Foreign Currency, Gold, Securities, Bonds, and Other Financial Assets Brought into Türkiye

Article 10 of the Law introduces Provisional Article 19 to the Corporate Tax Law, establishing a new Asset Repatriation Regime (Varlık Barışı).

Under the new regulation:

a) Declaration of Assets Held Abroad

Individuals and legal entities may declare the following assets held abroad to banks or intermediary institutions in Türkiye until 31 July 2027:

• Cash,
• Gold,
• Foreign currency,
• Securities, and
• Other capital market instruments.

The declared assets must be:

• Transferred to accounts opened in the declarant’s name with banks or intermediary institutions in Türkiye within two months from the declaration date; or
• If physically brought into Türkiye, deposited into such accounts within the same period.

Assets physically brought into Türkiye must also be declared to the Customs Administration.

b) Declaration of Assets Held in Türkiye but Not Recorded in the Books

Income and corporate taxpayers may declare cash, gold, foreign currency, securities, and other capital market instruments located in Türkiye but not recorded in their statutory books until 31 July 2027.

Such assets must be evidenced by depositing them with a bank or intermediary institution as of the declaration date.

Declared assets must be recorded in the statutory books of taxpayers maintaining books under the Tax Procedure Law.

For taxpayers keeping books on a balance sheet basis:

• The declared assets must be recorded in a special reserve fund account under equity.
• This reserve may not be withdrawn from the business or used for any purpose other than a capital increase for a period of two years.
• In the event of liquidation, the reserve will not be subject to taxation.

Taxpayers maintaining professional earnings books or operating account books must separately record the declared assets in their records.

These assets:

• Will not be taken into account in determining taxable income; and
• May be withdrawn from the business after two years without being considered in determining taxable income or distributable profits.

Individuals and entities without income or corporate tax liability may also benefit from the regime, provided that:

• Foreign assets are brought into Türkiye within two months; and
• Domestic assets are evidenced through deposits with banks or intermediary institutions.

Tax Rates

Banks and intermediary institutions will collect a tax on the declared assets and declare and pay such tax to the tax authorities on behalf of the declarants.

The standard tax rate is 5% of the declared asset value.

However, reduced rates apply if the declared assets are committed to be held in:

• Time deposit accounts,
• Government domestic debt securities issued under Law No. 4749,
• Lease certificates (sukuk), or
• Venture capital investment funds.

The applicable tax rates are:

For declarations made between 1 January 2027 and 31 July 2027, the above rates will be increased by 0.5 percentage points.

If the declaration period is extended by Presidential decision, declarations made after 31 July 2027 will be subject to an additional 0.5 percentage point increase, resulting in a total increase of 1 percentage point.

No stamp tax will be imposed on the commitment undertakings provided under this regime.

Tax Treatment

• Taxes paid under the Asset Repatriation Regime are not deductible and cannot be credited against any other tax liability.
• Losses arising from the disposal of declared assets are not deductible for income or corporate tax purposes.

Protection Against Tax Audits and Assessments

Amounts corresponding to the declared assets will be protected from tax audits and tax assessments.

Accordingly:

• No tax audit or tax assessment may be carried out solely with respect to the declared assets.
• If a tax audit or tax assessment conducted for other reasons identifies a tax base difference attributable to the declared assets, no assessment will be made to the extent that the declared asset amount equals or exceeds the identified tax base difference.
• If the tax base difference exceeds the declared asset amount, only the excess portion may be assessed.
• Tax base differences arising from causes unrelated to the declared assets remain fully assessable.

Loss of Protection

The protection against tax audits and assessments will not apply if:

• Foreign assets are not transferred to Türkiye within two months;
• Domestic assets are not deposited with banks or intermediary institutions within the prescribed period;
• Taxes assessed under the regime are not paid on time;
• The holding commitments are breached; or
• Other statutory requirements are not fulfilled.

In such cases, unpaid taxes will be collected together with default interest, although no tax loss penalty will be imposed.

Furthermore:

• Declarations made after the commencement of a tax audit or referral to the tax assessment commission will not prevent assessments resulting from such proceedings.
• Taxes already paid under the regime will not be refunded.
• No corrections to declarations may be made after the declaration period has expired.

Extension Authority

The President has been granted authority to extend the declaration deadline of 31 July 2027 for periods of up to six months at a time, not exceeding one additional year in total.

Effective Date

The amendment entered into force on the date of publication of the Law.

11. Incentives for Tech Start-Ups and Digital Companies

Article 11 of the Law introduces paragraphs 15 and 16 to Article 3 of Law No. 5746 on the Support of Research, Development and Design Activities, titled “Deductions, Exemptions, Supports and Incentives.”

Under the new regulation:

• Non-public companies holding a Technopreneurship Badge (Teknogirişim Rozeti) are provided with a simplified framework for carrying out conditional capital increases through convertible debt agreements.
• Entrepreneurs who have qualified as incubation entrepreneurs under Law No. 4691 and establish and operate companies that meet the definition of a digital company to be determined by the Ministry of Industry and Technology will benefit from an exemption from Union of Chambers and Commodity Exchanges of Türkiye (TOBB) membership fees for up to three years from the date of incorporation.

These measures are intended to facilitate access to financing for innovative start-ups and to support the growth of digital economy businesses in Türkiye.

The amendment entered into force on the date of publication of the Law.

12. Scope of the Tax Exemption Available to Employees in the Istanbul Financial Center Expanded

Article 12 of the Law amends Article 6 of Law No. 7412 on the Istanbul Financial Center, titled “Exemptions and Incentives Regarding Taxes and Other Financial Obligations.”

Under the amendment:

• The wage tax exemption applicable to personnel with professional experience acquired abroad has been broadened. Previously available only to employees of financial institutions holding a participant certificate, the exemption is now extended to employees of all participants operating within the Istanbul Financial Center.
• It has been expressly stipulated that personnel employed by Qualified Service Centers may not benefit simultaneously from both:
  • The wage tax exemption available under the Istanbul Financial Center regime; and
  • The income tax exemption provided under Article 23/20 of the Income Tax Law.

This amendment aims to enhance the attractiveness of the Istanbul Financial Center for internationally experienced professionals while preventing the concurrent application of overlapping tax incentives.

The amendment entered into force on the date of publication of the Law.

13. Duration of Tax Incentives Available in the Istanbul Financial Center Extended

Article 13 of the Law amends Provisional Article 1 of the Istanbul Financial Center Law, titled “Additional Exemption Regarding Corporate Tax and Fees.”

Under the amendment:

• The period during which the deduction rate applicable to income derived from financial service exports carried out within the Istanbul Financial Center by participant-certified financial institutions may be increased from 75% to 100% has been extended from 2031 to 2047.
• The exemption from financial activity fees applicable to the headquarters and branches of participant-certified financial institutions operating within the Istanbul Financial Center has been extended from 5 years to 20 years.

These amendments further strengthen the long-term attractiveness of the Istanbul Financial Center by providing extended tax and fee incentives to qualifying financial institutions.

The amendment entered into force on the date of publication of the Law.

You may access the relevant Law here.

Best Regards,

BİLGENER