Using Türkiye as a regional hub: qualified service centres, transit trade and the new-resident exemption under Law 7582

Published 16 October 2026 · 6 min read

Official Gazette 2026-06-04 · No. 33270 · Source

Law No. 7582, published in the Official Gazette on 4 June 2026 (No. 33270), carries the plain title “Law Amending Certain Laws”. Inside are three measures for groups that want to run regional functions from Türkiye: a new qualified service centre regime, a rewritten deduction for transit trade, and a 20-year exemption on foreign income for individuals who move to Türkiye.

This article looks at them from the point of view of a Chinese or Hong Kong group serving Europe, the Middle East and Central Asia. One caveat first: the ministry’s detailed procedures for qualified service centres have not been published in the Official Gazette as of 16 October 2026.

1. Qualified service centres

Which companies qualify

Law 7582 added a definition to the Foreign Direct Investment Law (No. 4875, additional article 1). A qualified service centre is a capital company (for example an A.Ş. or a Ltd. Şti.) that:

  • is set up to serve a related company or group that is actively operating in at least three different countries, and
  • earns at least 80% of its annual revenue from related companies abroad.

The services listed in the law include financial and strategic advisory, risk, cash and liquidity management, funding, budgeting and financial reporting, international accounting and compliance, audit, technology and data analysis, legal advisory (Turkish-law advice only through lawyers entitled to practise in Türkiye), brand management, human resources and training, and the coordination and management of sales, after-sales and technical support, R&D, sourcing, product testing and laboratory services.

Employees who perform these services directly, other than support staff, are “qualified service personnel”.

The corporate tax deduction

The tax benefit sits in article 10(1)(j) of the Corporate Tax Law. It is a deduction, not an exemption:

  • Rate: 95% of the earnings obtained from abroad exclusively from these activities; 100% for centres in industrial zones that the President approves on the basis of foreign investment density, and for participants of the Istanbul Financial Centre.
  • Duration: 20 accounting periods, starting with the period in which the centre begins operating.
  • Condition: the earnings must be transferred to Türkiye by the due date of the annual corporate tax return for that period.
  • Flexibility: the President may lower the rate to 50%, but not below, or raise it to 100%.
  • Start: earnings of periods beginning on or after 1 January 2026, starting with returns due from 1 July 2026.

This deduction, and the transit trade deduction below, also reduce the base of the 10% domestic minimum corporate tax, so that floor does not cancel them.

Wage exemption for qualified staff

The part of a qualified employee’s wage up to three times the gross minimum wage is exempt from income tax; five times in the approved industrial zones and for Istanbul Financial Centre participants. The President may set these multiples as low as one or double them. Staff who already use the Istanbul Financial Centre’s own wage exemption cannot also use this one.

Still missing: the procedures

The law leaves the detailed procedures to the Ministry of Industry and Technology, after consulting the Ministry of Treasury and Finance and the Ministry of Trade. As of 16 October 2026 they have not been published in the Official Gazette. Practical points remain open until then, for example how a company obtains or documents its status and how the three-country and 80% tests will be checked. You can model a structure now, but final decisions should wait for them.

2. Transit trade and trade intermediation

Law 7582 rewrote article 10(1)(i) of the Corporate Tax Law. The deduction dates from 2022; the new text sets it at 95%:

  • What qualifies: profits from selling goods bought abroad without bringing them into Türkiye, and from intermediating in purchases and sales of goods that take place abroad.
  • Rate: 95%, or 100% in the approved industrial zones and for Istanbul Financial Centre participants.
  • Conditions: the profit must be transferred to Türkiye by the annual return due date; for intermediation, the seller and the buyer of the goods must both be outside Türkiye.
  • Flexibility: the President may reduce the rate down to zero or raise it to 100%.
  • Start: as for service centres (2026 earnings, returns due from 1 July 2026).

For example, a Turkish trading company buys from factories in China and sells to customers in Central Asia, the Middle East or Europe, and the goods never enter Türkiye.

3. Moving to Türkiye: 20 years without Turkish tax on foreign income

Law 7582 added duplicate article 20/D to the Income Tax Law:

  • Who: individuals who become resident in Türkiye and had no domicile and no tax liability in Türkiye in the three calendar years before. Earlier Turkish tax liability arising from Turkish property income, income from movable capital (such as dividends or interest) or capital gains does not prevent this.
  • What: income earned outside Türkiye is exempt for 20 years. Income from Türkiye, such as a salary from the Turkish company, is not covered.
  • Filing: no return is filed for the exempt income. Related costs are not deductible, and foreign tax paid on it cannot be credited in Türkiye.
  • Inheritance: property passing by inheritance from a person using the exemption, during the exemption period, is taxed at 1%.
  • Start: individuals resident from 1 January 2026. Income Tax General Communiqué No. 333 (Official Gazette, 4 July 2026) sets out the application rules.

If the conditions turn out not to have been met, the tax not assessed is treated as lost tax (vergi ziyaı). Tax residence is also separate from immigration status: living and working in Türkiye still requires residence and work permits.

Large groups: check the global minimum tax

If your group’s consolidated revenue exceeded €750 million in at least two of the four preceding years, the 15% global minimum tax applies. The 95% deductions can bring the Turkish effective tax rate below 15%, and Türkiye’s domestic top-up tax may then collect the difference.

Take special care if a Turkish company will hold the group’s subsidiaries in other countries for a mainland Chinese parent. Because mainland China is not on Türkiye’s list of countries applying a qualified income inclusion rule (Presidential Decision 11511), the Turkish company can itself become liable as an intermediate parent; it then registers for the global top-up tax and files the global return, and a notification form is not enough. Background: global minimum tax for Chinese and Hong Kong groups.

What this means for you

  1. Map the group: where the related companies operate, and what share of the Turkish company’s revenue will come from related companies abroad.
  2. Match the activities to the law’s list, and check whether a 100% location is realistic.
  3. Plan the cash: both deductions require the profit to reach Türkiye by the annual return due date.
  4. Plan the people: the wage exemption and the 20-year exemption can matter as much as the corporate tax deduction.
  5. Wait for the procedures before committing to the service centre route. The transit trade deduction and the new-resident exemption already apply.

A service centre has to be a capital company; for a foreign group that normally means setting up a Turkish company first (company formation). We then keep the books and file the returns in which the deductions are claimed (bookkeeping and tax filing). If the Turkish company will be owned through Hong Kong, see our article on the Hong Kong–Türkiye tax treaty, which applies in Türkiye from 1 January 2027.

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