With the Presidential Decree No. 11257 (“Decree”) published in the Official Gazette dated 30 April 2026 and numbered 33239, significant amendments have been introduced to certain rates under the Income Tax Law and the Corporate Tax Law.
Through these amendments, tax advantages particularly applicable to income derived from service exports and foreign subsidiary income have been expanded, and the implementation conditions have been revised in favor of taxpayers.
Under the previous regime, 80% of the income derived from the export of certain services could be deducted from the income/corporate tax base. With Decree, this rate has been increased to 100%.
Accordingly, income derived from the following activities:
- Software, architecture, engineering, design, data processing, data analytics, call center services, medical reporting, accounting, certification and similar services, as well as education and healthcare services, may be fully deductible from the tax base, provided that the relevant conditions are met.
The key conditions in this respect include:
- The services must be rendered to non-residents and benefit must be realized abroad, and
The income must be transferred to Türkiye within the relevant tax filing period.
The Decree also introduces significant changes to the exemption regime applicable to foreign subsidiary income:
- The minimum shareholding requirement has been reduced from 50% to 20%, while the exemption rate has been increased from 50% to 80%.
Accordingly, income derived by Turkish resident companies from their foreign subsidiaries may benefit from a higher exemption rate with a lower shareholding threshold.
Similarly, for individuals, the minimum shareholding requirement for the exemption applicable to foreign dividend income has also been reduced to 20%. These amendments entered into force on 30 April 2026 (the date of publication) and will apply to taxation periods starting from 1 January 2026.
