Circular 2026-036<\/p>\n\n\n\n
Law No. 7582 Amending Certain Laws was Published in the Official Gazette<\/strong><\/p>\n\n\n\n Significant changes have been made to tax legislation with Law No. 7582, Amending Certain Laws, published in the Official Gazette dated June 4, 2026, and numbered 33270.<\/p>\n\n\n\n The amendments made by Law No. 7582 on Amending Certain Laws are summarized as follows.<\/p>\n\n\n\n 1. Extension of the Repayment Period<\/strong><\/p>\n\n\n\n Article 1 and the amendment made to Article 48 of Law No. 6183 on the Procedure for Collection of Public Debts, dated June 4, 2026, regarding the deferral period 36 months to 72 months<\/strong> and the unsecured deferral amount is 50,000 TL 1.000.000<\/strong> It has been converted to TL.<\/p>\n\n\n\n Accordingly, if the payment of the public debt on the due date, the execution of a seizure, or the conversion of the seized property into cash would place the public debtor in a very difficult situation, the creditor public administration or the authorities it authorizes may postpone the public debt for a period not exceeding 72 months, with interest, provided that the debtor requests it in writing and provides collateral.<\/p>\n\n\n\n 2. Benefit of exemption from wages for benefits provided by issuing shares to service providers<\/strong><\/p>\n\n\n\n With the amendment made to Article 17 of the Income Tax Law by Article 3 of the Law, the amount considered for income tax exemption on stock options granted to employees by technology entrepreneurship companies has been determined as two times the gross wage of the employee in the relevant year.<\/p>\n\n\n\n Furthermore, the periods for collecting taxes not levied in due time, depending on the holding periods of shares, have been redesignated as follows.<\/p>\n\n\n\n Shares acquired by the service provider in this manner; from the date of acquisition two<\/strong> the entire tax exempted if disposed of within the same year, three<\/strong> Aunt Four<\/strong> y\u0131l i\u00e7erisinde elden \u00e7\u0131kar\u0131lmas\u0131 halinde istisna edilen verginin %75\u2019i, five<\/strong> Aunt six<\/strong> y\u0131l i\u00e7erisinde elden \u00e7\u0131kar\u0131lmas\u0131 halinde istisna edilen verginin %25\u2019i, vergi ziya\u0131 cezas\u0131 uygulanmaks\u0131z\u0131n gecikme faizi ile birlikte i\u015fverenden tahsil edilir.<\/p>\n\n\n\n 3. Income tax exemption for earnings and revenues obtained outside of Turkey and application of reduced rate for inheritance and transfer tax<\/strong><\/p>\n\n\n\n Under Article 4 of the Law, which added Article 20\/D to the Income Tax Law, gains and revenues earned outside of Turkey by individuals who have not been residents of Turkey in the last three calendar years, on their earnings and revenues obtained outside of Turkey for 20 years<\/strong> is exempt from income tax.<\/p>\n\n\n\n The fact that natural persons have tax liability in Turkey due to real estate capital gains, portfolio capital gains, or capital gains from the sale of assets before they are covered by this clause will not prevent them from benefiting from this exemption.<\/p>\n\n\n\n On the other hand, pursuant to Article 2 of the Law and the amendment made to Article 16 of the Inheritance and Gift Tax Law, for those benefiting from the income tax exemption under the aforementioned Repeated Article 20\/D, it has been determined that, during the period in which the exemption is in effect, the inheritance and transfer tax shall be applied at a rate of %1 on property transfers occurring through inheritance that are subject to such tax.<\/p>\n\n\n\n 4. Qualified Service Center Personnel Fee Exemption<\/strong><\/p>\n\n\n\n With the 5th article of the Law, the 20th clause added to the 23rd article of the Income Tax Law, titled \u2019In Salaries and Wages,\u201c has exempted the portion of the salaries of qualified service personnel employed in qualified service centers, not exceeding three times the gross minimum wage, from income tax. The exemption, which entered into force on June 4, 2026, will be applied as five times the gross minimum wage for qualified service centers operating in industrial zones and the Istanbul Financial Center, as approved by the President.<\/p>\n\n\n\n 5. Qualified Service Center\u00a0<\/strong><\/p>\n\n\n\n Kanunun 6\u2019nc\u0131 maddesiyle, Do\u011frudan Yabanc\u0131 Yat\u0131r\u0131mlar Kanununa eklenen EK Madde 1 ile \u201cnitelikli hizmet merkezi\u201d tan\u0131mlanm\u0131\u015f ve ; en az \u00fc\u00e7 \u00fclkede faaliyet g\u00f6steren ve gelirinin en az %80\u2019ini yurt d\u0131\u015f\u0131ndan elde eden \u015firketlerin bu kapsamda de\u011ferlendirilece\u011fi belirlenmi\u015ftir.<\/p>\n\n\n\n Additionally, the services that can be offered by these centers have been determined as follows. <\/p>\n\n\n\n Financial consulting, 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, auditing, digital transformation and technology consulting, investment and data analysis, legal consulting (legal consulting for domestic operations or Turkish law, to be obtained only from a lawyer or law firm capable of providing services within the scope of Law No. 1136 on Lawyers), promotion, brand management, human resources and training services, and coordination and management services related to these services, <\/p>\n\n\n\n b. Coordination and management services related to activities such as sales, after-sales support, technical support, research and development, external procurement, testing of newly developed products, and laboratory services. <\/p>\n\n\n\n Employees who directly perform these services and are not support staff are qualified service personnel. <\/p>\n\n\n\n In this case, with the addition to Article 23 of the GVK; the wages of qualified service personnel employed in the qualified service centers defined above The portion not exceeding 3 times the gross minimum wage is exempt from income tax.<\/strong> will be considered as. <\/p>\n\n\n\n 6. Transit trade profit discount<\/strong><\/p>\n\n\n\n With the 7th article of the Law, in the 10th article of the Corporate Tax Law, titled \u2019Other Deductions\u201c I told you<\/strong> yap\u0131lan de\u011fi\u015fiklik ile yurt d\u0131\u015f\u0131ndan sat\u0131n al\u0131nan mallar\u0131n T\u00fcrkiye\u2019ye getirilmeksizin yurt d\u0131\u015f\u0131nda sat\u0131lmas\u0131ndan veya yurt d\u0131\u015f\u0131nda ger\u00e7ekle\u015ftirilen mal al\u0131m sat\u0131mlar\u0131na arac\u0131l\u0131k edilmesinden elde edilen kazan\u00e7lar\u0131n %95\u2019inin kurumlar vergisi matrah\u0131ndan indirilebilmesine ili\u015fkin d\u00fczenleme yap\u0131lm\u0131\u015ft\u0131r.<\/p>\n\n\n\n \u0130ndirim oran\u0131 End\u00fcstri B\u00f6lgeleri Kanunu kapsam\u0131nda kurulan ve yabanc\u0131 yat\u0131r\u0131m yo\u011funlu\u011funa g\u00f6re Cumhurba\u015fkan\u0131nca uygun bulunan end\u00fcstri b\u00f6lgelerinde faaliyet g\u00f6steren kurumlar ile \u0130stanbul Finans Merkezi Kanunu kapsam\u0131nda kat\u0131l\u0131mc\u0131 belgesi alarak \u0130stanbul Finans Merkezi B\u00f6lgesinde faaliyet g\u00f6steren kurumlar bak\u0131m\u0131ndan %100 olarak uygulanacakt\u0131r.<\/p>\n\n\n\n To benefit from the discount, the income must be transferred to Turkey by the due date of the annual corporate tax return for the accounting period in which the income was earned, and the seller and buyer of the goods related to the intermediation activity must not be located in Turkey.<\/p>\n\n\n\n 7. Corporate Tax Discount in a Qualified Service Center<\/strong><\/p>\n\n\n\n With Article 7 of the law, added to Article 10 of the Corporate Tax Law, titled \u2019Other Deductions,\u201c j bendi<\/strong> ile Do\u011frudan Yabanc\u0131 Yat\u0131r\u0131mlar Kanunu kapsam\u0131nda nitelikli hizmet merkezi olarak faaliyette bulunan kurumlar\u0131n, m\u00fcnhas\u0131ran bu faaliyetleri kapsam\u0131nda yurt d\u0131\u015f\u0131ndan elde ettikleri kazan\u00e7lar\u0131n %95\u2019inin kurumlar vergisi matrah\u0131ndan indirilebilmesine ili\u015fkin d\u00fczenleme yap\u0131lm\u0131\u015ft\u0131r.<\/p>\n\n\n\n \u0130ndirim oran\u0131 4737 say\u0131l\u0131 Kanun kapsam\u0131nda kurulan end\u00fcstri b\u00f6lgelerinden, b\u00f6lgenin yabanc\u0131 yat\u0131r\u0131m yo\u011funlu\u011funa g\u00f6re Cumhurba\u015fkan\u0131nca uygun bulunanlar ile 7412 say\u0131l\u0131 Kanun h\u00fck\u00fcmlerine g\u00f6re kat\u0131l\u0131mc\u0131 belgesi alarak \u0130stanbul Finans Merkezi B\u00f6lgesinde nitelikli hizmet merkezi olarak faaliyette bulunan kurumlar bak\u0131m\u0131ndan bu oran %100 olarak uygulan\u0131r.<\/p>\n\n\n\n This discount is applied for twenty fiscal periods, starting from the fiscal period in which the qualified service center commenced operations, provided that the earnings are transferred to Turkey by the due date for filing the annual corporate tax return for the fiscal period in which the earnings are realized.<\/p>\n\n\n\n 8. Reduced Corporate Tax on Earnings from Production and Agricultural Activities<\/strong><\/p>\n\n\n\n With the amendment made to Article 32 of the Corporate Tax Law by Article 8 of the Law, for earnings obtained in the 2027 and following tax periods; the corporate tax rate for profits exclusively obtained from production activities by corporations that have an industrial registry certificate and are actually engaged in production activities, and for profits exclusively obtained from agricultural production activities by corporations engaged in agricultural production activities. %12,5<\/strong> has been determined.<\/p>\n\n\n\n 9. Domestic Minimum Corporate Tax Base<\/strong><\/p>\n\n\n\n With Article 9 of the Law, the \u2019Corporate Tax Law\u201cDomestic minimum corporate tax<\/strong>\u201dWith the amendment made to Article 32\/C titled \"\", it has been enabled that the earnings deductions provided within the scope of transit trade and qualified service centers added to Articles 7 and 10 of the KVK (Corporate Tax Law) can be deducted from the minimum corporate tax base.<\/p>\n\n\n\n Additionally, with the added subsection (d), it has been made possible to deduct the earnings reduction mentioned in subsection (a) of the first paragraph of Article 6 of Law No. 7412 on the Istanbul Financial Center from the minimum corporate tax base.<\/p>\n\n\n\n 10. Declaration of assets located abroad and domestically, (Asset amnesty)\u00a0<\/strong><\/p>\n\n\n\n With Article 10 of the Law, provisional Article 19 was added to the Corporate Tax Law, bringing a new \u2019Asset Amnesty\u2019 regulation, as it is known.<\/p>\n\n\n\n Reporting of Assets Located Abroad<\/strong><\/p>\n\n\n\n Natural and legal persons will be able to bring their money, gold, foreign currency, securities, and other capital market instruments held abroad to Turkey by reporting them to banks or intermediary institutions until July 31, 2027.<\/p>\n\n\n\n foreign assets reported under the provision, from the date of reporting within two months<\/strong> Assets must be transferred to accounts opened at banks or brokerage firms in Turkey, or physically brought into Turkey and deposited into these accounts. For assets physically brought into the country, it is envisioned that they will be evidenced by a declaration to the Customs Administration.<\/p>\n\n\n\n Domestic asset reporting<\/strong><\/p>\n\n\n\n Money, gold, foreign currency, securities, and other capital market instruments owned by income or corporate taxpayers that are located in Turkey but not recorded in legal books can be reported to banks or brokerage firms until July 31, 2027. <\/p>\n\n\n\n These domestic entities, as of the notification date<\/strong> It is mandated to be evidenced by depositing it into a bank or brokerage firm. <\/p>\n\n\n\n Recording of assets by taxpayers<\/strong><\/p>\n\n\n\n Assets that are both domestically and internationally reported must be recorded in the legal books by taxpayers who keep records in accordance with Law No. 213 on Tax Procedure. For taxpayers who keep books on the balance sheet basis, it is stipulated that a special reserve fund account be opened in the liabilities for the reported assets; it is regulated that this fund account cannot be withdrawn from the business until two years have passed from the date of reporting and cannot be used for any purpose other than adding to the capital. Furthermore, it is regulated that the said assets will not be taken into account in the determination of period earnings and can be withdrawn from the business at the end of the two-year period without being considered for the determination of taxable earnings and distributable earnings.<\/p>\n\n\n\n Those who are not liable for taxes<\/strong><\/p>\n\n\n\n Those who do not have income tax or corporate tax liability may benefit from the provisions of this article without meeting the conditions set forth in the fourth paragraph, provided that they bring the assets they have declared to Turkey within the period specified in the second paragraph, and prove their domestic assets by depositing them in banks or intermediary institutions as of the declaration date.<\/p>\n\n\n\n Tax declaration and rate<\/strong><\/p>\n\n\n\n According to the regulation, banks and broker-dealers, with respect to the assets reported to them, may require the reporting party to pay a fee based on the value of the assets at a 1:3:5 ratio<\/strong> They will declare the tax they collect in advance to the tax office they are affiliated with with a declaration as a tax liable by the fifteenth day of the month following the notification and pay it within the same period.<\/p>\n\n\n\n On the other hand, the possibility of applying the said rate at a discount, depending on the condition, has also been provided.<\/p>\n\n\n\n in the reported entity's term accounts, Turkish Treasury bonds issued within the scope of Law No. 4749, lease certificates, or venture capital investment funds;<\/p>\n\n\n\n If a commitment is made to hold the asset for at least five years, the tax rate is %0,<\/p>\n\n\n\n If a commitment is made to hold the asset for at least four years, the tax rate is %1,<\/p>\n\n\n\n If a commitment is made to hold the investment for at least three years, the tax rate is %2,<\/p>\n\n\n\n If a commitment is made to hold the asset for at least two years, the tax rate is %3,<\/p>\n\n\n\n If a commitment is made to hold the asset for at least one year, the tax rate of %4 applies. <\/p>\n\n\n\n Additionally, a half-point increase will be applied to these rates for notifications made from January 1, 2027, to July 31, 2027, inclusive.<\/strong>.If the date of 07\/31\/2027 is extended by authorization, the tax rate to be applied to notifications made after this date will be 1 point higher in total, with an additional half-point increase. No stamp duty will be collected on the undertakings to be issued within the scope of this paragraph.<\/p>\n\n\n\n Expense record<\/strong><\/p>\n\n\n\n The tax paid under this article cannot be deducted as an expense under any circumstances and cannot be offset against any other tax. Losses arising from the disposal of assets subject to declaration will not be accepted as expenses or deductions for income or corporate tax purposes.<\/p>\n\n\n\n Review and historical analysis<\/strong><\/p>\n\n\n\n No tax audit or assessment shall be made, in any event, with respect to the amounts covered by the declared assets. However, measures to be taken under other legislation shall not be affected by this regulation. <\/p>\n\n\n\n Tax assessments initiated for other reasons, where it is determined that the difference in the tax base found as a result of tax inspections or decisions of the assessment commission arose due to assets declared under this article, and where the declared asset amount is equal to or greater than the found tax base difference, no tax assessment shall be made regarding the tax base difference. If the found tax base difference is larger than the declared asset amounts, even if it is determined that it arose due to assets declared under this article, tax shall be assessed only on the difference amount. If a tax base difference is determined as a result of tax inspections or decisions of the assessment commission for reasons other than the assets subject to declaration, tax shall be assessed without deducting the amounts declared under this article from the found tax base difference.<\/p>\n\n\n\n On the other hand, it is stipulated that the said examination and assessment protection cannot be utilized if the declared assets are not brought to Turkey within the specified period, not deposited into bank or brokerage accounts, if the accrued taxes are not paid on time, or if the given commitments are not complied with. Furthermore, it is provided that amendments to declarations cannot be made after the declaration period ends.<\/p>\n\n\n\n 11. Financing and Exemptions for Technology Startups<\/strong><\/p>\n\n\n\n Article 11 of the Law on Supporting Research, Development and Design Activities No. 5746, \u2019Discount, exception, support, and incentive elements<\/strong>\u201dThe clauses added to Article 3 titled \"Tax Incentives During the Transition to Digitalization\" provide exceptions to certain provisions of the Turkish Commercial Code for transactions carried out by companies with a techno-entrepreneur badge under convertible debt agreements; furthermore, digital companies are granted an exemption from chamber fees during their establishment and operational periods.<\/p>\n\n\n\n 12. Scope of Istanbul Financial Center Incentives<\/strong><\/p>\n\n\n\n\n
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