A lawyer in Turkey advising foreign investors on the 2026 tax package now works from an enacted statute rather than a political announcement. On 24 April 2026, at the Türkiye Yüzyılı Yatırım İçin Güçlü Merkez Programı, the President set out a broad framework of tax measures aimed at high-net-worth individuals, exporters, and multinational groups. On 4 June 2026, the operative parts of that framework became law when Law No. 7582 was published in the Official Gazette No. 33270. The distinction matters more than it may appear, because the enacted statute is narrower and more precise than the announcement, and several headline figures from April either changed in the drafting or did not pass at all. This guide explains what Law No. 7582 actually contains, separates the enacted measures from the announced-but-not-legislated ones, and shows how the pieces fit together for a foreign investor planning a move, a repatriation, or a restructuring. Practice may vary by authority and year, and implementing communiqués from the Ministry of Treasury and Finance were still pending at the time of writing.
From Announcement to Statute: What Changed Between April and June
An Istanbul Law Firm reading the package today has to hold two documents in mind at once: the 24 April programme, which is political and aspirational, and Law No. 7582, which is the enforceable text. The announcement described seven broad axes, including a twenty-year exemption for new residents, a wealth amnesty, a one per cent inheritance rate, an Istanbul Finance Center expansion, dramatic corporate tax cuts for exporters, a One-Stop Office for investors, and a full exemption for software and engineering exports. Law No. 7582, accepted by the Grand National Assembly on 21 May 2026 and published on 4 June 2026, enacted some of these faithfully, reshaped others during drafting, and left several as policy intentions without statutory form. A foreign investor who plans against the April headlines rather than the June statute risks building on figures that no longer exist.
A Turkish Law Firm summarising the enacted measures would list them precisely. Law No. 7582 inserted a new Mükerrer Article 20/D into the Income Tax Law, exempting twenty years of foreign-source income for qualifying new residents; amended Article 16 of the Inheritance and Transfer Tax Law to tax inheritance at one per cent for those beneficiaries; added Provisional Article 19 to the Corporate Tax Law to create the 2026 wealth amnesty; defined the qualified service centre in the Foreign Direct Investment Law and granted it, together with transit trade, a deduction of ninety-five to one hundred per cent under Article 10 of the Corporate Tax Law; set a 12.5 per cent corporate tax rate on production earnings under Article 32; extended the Istanbul Finance Center incentive period from 2031 to 2047; lengthened the public-debt deferral period and raised the unsecured deferral ceiling; and made several research-and-development and start-up changes. Each of these is examined below, with the figures stated as the statute states them.
An English speaking lawyer in Turkey is equally careful about what did not become law. The April headline of a nine per cent corporate tax rate for manufacturer-exporters and fourteen per cent for other exporters does not appear in Law No. 7582; the enacted corporate rate measure is the 12.5 per cent production rate, which is a different instrument with different conditions. The announced increase of the software, engineering, architecture, and design export deduction from eighty to one hundred per cent is not among the articles of Law No. 7582; that deduction remains at its current level. The One-Stop Office, the project-based stabilisation clause, and the Terminal İstanbul project were described as programme objectives and do not take the form of enacted provisions in this statute. Treating these as live law would be a mistake, and a careful analysis keeps them in the category of announced policy until and unless they are legislated. Practice may vary by authority and year.
The Twenty-Year Foreign Income Exemption (Article 20/D)
Turkish lawyers who advise inbound relocation treat the twenty-year exemption as the centre of gravity of the whole package. Law No. 7582 inserted Mükerrer Article 20/D into the Income Tax Law (Law No. 193). In substance, a natural person who becomes a Turkish tax resident, and who in the three calendar years before becoming resident had neither a domicile in Turkey nor a tax liability in Turkey, may keep foreign-source income and earnings outside the Turkish income tax base for twenty years. No annual return is filed for the exempt income, and where the conditions are later found not to have been met, the untaxed amounts are treated as lost revenue and assessed with the associated consequences. The provision applies to income derived from 1 January 2026 by those treated as resident, and entered into force on publication on 4 June 2026.
A lawyer in Turkey explaining the rule starts with the three-year look-back, because eligibility turns on it. The two disqualifiers in that window are a Turkish domicile and a Turkish tax liability, and the statute is concerned with active liability of the kind that arises from commercial or professional activity or from being a full taxpayer. A limited, passive historical connection — for example rental income from a Turkish property, income from movable capital, or a capital gain — does not by itself spend eligibility in the way that domicile or active liability does. This distinction is decisive for diaspora returnees and for foreign nationals who once held a minor Turkish source of income, and it is developed in full in our dedicated guide. For the complete mechanics of residency, the passive-income carve-out, the absence of a foreign tax credit, and the interaction with double taxation treaties, see our twenty-year foreign income exemption guide.
An Istanbul Law Firm also flags the companion inheritance benefit, because the same statute amended Article 16 of the Inheritance and Transfer Tax Law (Law No. 7338). For a person who benefits from the Article 20/D exemption, transfers by inheritance occurring within the exemption period are taxed at one per cent. Turkey's ordinary inheritance tax is progressive and rises into double digits on larger estates, so a fixed one per cent rate during the exemption window is a material reduction rather than a marginal one. For a client whose estate planning was part of the reason to consider Turkey, this companion rate can rival the income exemption in importance, and the two should be planned together rather than separately.
The 2026 Wealth Amnesty (Provisional Article 19)
A Turkish Law Firm treats the wealth amnesty as the natural counterpart to the income exemption, because one addresses future income and the other addresses the existing stock of wealth. Law No. 7582 added Provisional Article 19 to the Corporate Tax Law (Law No. 5520). Real and legal persons may declare money, gold, foreign currency, securities, and other capital market instruments that are held abroad, or that are within Turkey but unrecorded in the books, by 31 July 2027, a deadline the President may extend in further periods of up to one year in total. The declared amounts receive protection from tax examination and assessment within the limits the statute sets, and a bank or intermediary institution collects the applicable rate at source and remits it to the tax office.
An English speaking lawyer in Turkey explains the rate structure carefully, because it rewards commitment. The base rate is five per cent, reduced to four, three, two, one, and ultimately zero per cent according to whether the declared assets are held for one, two, three, four, or five years in time deposits, government domestic debt securities, lease certificates, or venture capital funds. A half-point is added for declarations made in a defined early window, and a further point applies during any extension period. Foreign assets must be brought to a Turkish bank or intermediary account within two months of declaration, with physical imports substantiated through the Customs Administration. Real estate is outside the scope of the amnesty. The full mechanics, the special fund account for unrecorded domestic assets, the limits of the audit protection, and the interaction with the income exemption are set out in our 2026 wealth amnesty guide.
A lawyer in Turkey also places the 2026 amnesty in its historical line, because the structure is recognisable. Turkey has legislated wealth amnesties repeatedly since 2008, through a sequence of laws that varied the rates, the deadlines, and the holding conditions, and the 2026 programme follows that pattern with its own rate scale and its own window. The lesson from the earlier programmes is consistent: the most favourable treatment is reserved for early, committed declarations, and the protection is unavailable once an examination has begun. A client weighing whether to declare should therefore decide deliberately and early rather than wait for the deadline to approach. Practice may vary by authority and year, and the implementing communiqué will set out the documentary detail.
The Istanbul Finance Center: Extension to 2047 and the New Deductions
An Istanbul Law Firm advising on the financial centre starts with the single most important change Law No. 7582 made to it: the incentive period was extended. The Istanbul Finance Center Law (Law No. 7412) previously ran its core deduction to 2031; the statute replaced that horizon with 2047, and adjusted the related period reference from five years to twenty. For an institution weighing whether to take up a participant certificate, this transforms the planning horizon, because the central benefit now has a two-decade runway rather than a window closing within a few years. The financial service export deduction available to participants, applied in full under the transitional provision, now extends on that longer basis.
A Turkish Law Firm then turns to the two new deductions Law No. 7582 created under Article 10 of the Corporate Tax Law, because they reach beyond the financial centre. The first concerns transit trade: earnings from buying goods abroad and selling them abroad without bringing them into Turkey, or from intermediating such trades, may be deducted at ninety-five per cent, rising to one hundred per cent for institutions operating in the Istanbul Finance Center or in industrial zones approved for this purpose. The conditions are that the earnings are transferred to Turkey by the corporate tax return deadline and that the buyer and seller of the intermediated goods are both outside Turkey. The second concerns the qualified service centre, defined by Law No. 7582 in the Foreign Direct Investment Law (Law No. 4875): a qualified service centre may deduct ninety-five per cent of the foreign-source earnings from its qualifying activity, again rising to one hundred per cent inside the financial centre or approved zones, for twenty accounting periods. Both deductions apply to earnings from accounting periods beginning on or after 1 January 2026, in returns filed from 1 July 2026.
An English speaking lawyer in Turkey reads the qualified service centre as the enacted form of what the April announcement loosely called a regional headquarters incentive. The statute does not create a free-standing "regional headquarters" category with its own twenty-year exemption; it creates the qualified service centre, which a group managing functions for related parties across several countries can use to house cross-border service and intermediation earnings at a near-zero effective rate. The definitional conditions, the eighty per cent related-party revenue threshold, the multi-country requirement, and the practical steps to obtain participant or centre status are set out in our financial-centre materials. For the umbrella treatment of the centre, its participants, and the qualified service centre regime, see our Istanbul Finance Center hub.
A lawyer in Turkey draws the practical line between the financial-centre participant and the qualified service centre, because they serve different clients. The participant certificate suits an institution carrying on financial activity for non-resident clients — banking, insurance, portfolio and fund management, reinsurance, and similar services — and its benefit is the financial service export deduction now running to 2047. The qualified service centre suits a group that concentrates non-financial cross-border functions, earning predominantly from related parties across at least three countries, and its benefit is the ninety-five to one hundred per cent deduction on qualifying foreign-source earnings over twenty accounting periods. A group that mistakes one for the other applies the wrong conditions and risks losing the deduction it actually qualifies for, so the threshold question is always which regime the activity fits before any structuring begins.
The Corporate Tax Picture: The 12.5 Per Cent Production Rate, Not Nine or Fourteen
A lawyer in Turkey has to be exact here, because this is where the gap between announcement and statute is widest and where a careless reading does real harm. The April programme spoke of cutting the corporate tax rate to nine per cent for manufacturer-exporters and fourteen per cent for other exporters. That formulation did not become law. What Law No. 7582 enacted, by adding a new paragraph to Article 32 of the Corporate Tax Law, is a 12.5 per cent rate on the earnings that a company with an industrial registry certificate derives purely from its production activity, and the same rate for the production earnings of companies engaged in agricultural production. Earnings outside that production activity remain taxed at the general rate. The measure applies to earnings from the 2027 tax period onwards.
A Turkish Law Firm places that rate in the existing structure to show its real weight. Turkey's general corporate tax rate is twenty-five per cent. Exporters already benefit from a five-point reduction on export earnings, bringing them to twenty per cent, and producers from a one-point reduction, mechanisms that pre-date Law No. 7582. Against that baseline, a 12.5 per cent rate on production earnings is close to halving the general rate for qualifying activity, which is substantial — but it is a production-based rate reached through Article 32, not the export-based nine and fourteen per cent figures that circulated in April. A company modelling its 2027 position should use 12.5 per cent on qualifying production earnings, confirm that it holds an industrial registry certificate and is actually engaged in production, and note that earnings benefiting from this rate do not separately stack the export deduction.
An English speaking lawyer in Turkey works a simple illustration to keep the rate honest. A foreign-owned company with an industrial registry certificate that earns its profit from manufacturing applies 12.5 per cent to that production profit from the 2027 period, rather than the twenty-five per cent general rate, so on production earnings the charge is roughly halved. The same company's non-production income — for example financial income or earnings from activities outside the registry — stays at the general rate, which is why the separation of production from non-production earnings in the accounts is not a formality but the thing that determines how much of the profit reaches the lower rate. Where the company also exports, it cannot stack the five-point export reduction on the same production earnings that already enjoy the 12.5 per cent rate; it chooses the regime that produces the better result for each stream. The modelling, in other words, is line-by-line rather than a single blended figure.
An Istanbul Law Firm draws the practical conclusion for foreign-owned manufacturers. The benefit is genuine but conditional and prospective: it requires the industrial registry certificate and actual production, it is confined to production earnings, and it begins with the 2027 tax period rather than immediately. For a foreign investor evaluating a Turkish manufacturing footprint, this rewards a clean structure in which production earnings are clearly identifiable and properly documented, and it counsels against assuming the headline export figures from the announcement. For the existing corporate tax framework that continues to apply around this new rate, foreign companies can consult our broader corporate tax materials and confirm their position before relying on any single figure. Practice may vary by authority and year.
How the Global Minimum Tax Constrains the Benefits
An English speaking lawyer in Turkey cannot present the corporate incentives without the global minimum tax, because for large groups it sets a floor that the incentives cannot pierce. Turkey enacted the local and global minimum complementary corporate tax through Law No. 7524, published in the Official Gazette on 2 August 2024. It targets multinational groups whose ultimate parent reports annual consolidated revenue of 750 million euro or more in at least two of the four preceding periods, in line with the OECD's global rules. The global minimum rate is fifteen per cent; where a group's effective rate in a country falls below that, a top-up is collected to reach it.
A Turkish Law Firm explains the consequence for the package's incentives. For a multinational group within the 750 million euro scope, a low Turkish effective rate produced by the production rate, the transit trade deduction, or the qualified service centre deduction can be met by a top-up that brings the effective rate back to fifteen per cent, whether through Turkey's own complementary tax or through another country's rules. Turkey's domestic minimum complementary tax, also introduced by Law No. 7524 and effective for periods from 2025, is designed so that Turkey itself collects that top-up rather than ceding it abroad. The income inclusion rule applied to fiscal years from 1 January 2024 and the undertaxed profits rule from 1 January 2025. The practical effect is that the most generous deductions in Law No. 7582 deliver their full benefit to groups below the threshold, while in-scope groups should model the incentives against the fifteen per cent floor rather than assume the headline rate.
A lawyer in Turkey therefore advises in-scope and out-of-scope clients differently. A privately held manufacturer or a mid-sized service exporter below the threshold can plan straightforwardly on the enacted rates and deductions. A large multinational must run the Turkish position through the global minimum tax computation, consider the interaction with its home-country rules, and weigh the non-tax reasons to locate in Turkey alongside an effective rate that the minimum tax may equalise. Conflating these two categories is one of the more common and costly errors in reading the package, and the distinction should be drawn at the outset of any structuring exercise. Practice may vary by authority and year.
What Was Announced But Not Enacted
An Istanbul Law Firm earns its fee partly by telling clients what is not there. Three prominent items from the April programme are not enacted provisions of Law No. 7582, and a foreign investor should treat them accordingly. The first is the nine and fourteen per cent corporate tax rates for exporters, which, as set out above, were not legislated in this form; the enacted instrument is the 12.5 per cent production rate. The second is the increase of the export-services deduction for software, engineering, architecture, and design from eighty to one hundred per cent. That deduction exists under the Income Tax Law and the Corporate Tax Law and currently stands at eighty per cent following a 2023 amendment, but the increase to one hundred per cent is not among the articles of Law No. 7582, and it should not be presented to clients as enacted.
A Turkish Law Firm is equally clear about the administrative and protective measures. The One-Stop Office, described in April as a single coordinated point for company formation, work and residence permits, tax and social security, and land, incentive, and environmental procedures under the coordination of the Presidency's Investment and Finance Office, is a programme objective rather than a new statutory mechanism in this law. A version of a one-stop arrangement already exists within the Istanbul Finance Center under its own legislation, coordinated by the Finance Office, but the broad investor-wide office described in April is not legislated here. The project-based stabilisation clause, offering protection against future tax changes for qualifying large investments, and the Terminal İstanbul project at the former airport site were likewise described as objectives, with the announcement using the language of measures to be taken rather than measures enacted.
An English speaking lawyer in Turkey notes the one area where a start-up measure did pass, to avoid the opposite error of dismissing everything not on the headline list. Law No. 7582 made changes in the research-and-development field, broadening the income tax treatment of share-based awards granted by qualifying technology start-ups to their employees and easing the use of convertible-debt arrangements for badged non-public companies, alongside fee relief for certain incubator digital companies. These are real, enacted changes, even though they sit outside the seven headline axes. The discipline the investor needs is neither to assume the announcement is law nor to assume nothing passed, but to check each measure against the enacted text. A measure that is announced but not legislated may still arrive in a later statute, so the right posture is to monitor rather than to dismiss; but it cannot be relied on, structured around, or presented to a client as a current entitlement until it appears in an enacted provision with an effective date. Practice may vary by authority and year, and the status of each announced-but-unlegislated measure should be reviewed as further legislation is published.
The Effective Dates That Govern Planning
A lawyer in Turkey organises the package around its dates, because the benefits do not all begin at once and a plan built on the wrong date fails quietly. The twenty-year foreign income exemption applies to income derived from 1 January 2026 by those treated as resident, and entered into force on publication on 4 June 2026. The one per cent inheritance rate, tied to that exemption, took effect on publication. The wealth amnesty runs to its 31 July 2027 declaration deadline, subject to extension, with the two-month repatriation rule running from each declaration. The transit trade and qualified service centre deductions apply to accounting periods beginning on or after 1 January 2026, in returns filed from 1 July 2026.
A Turkish Law Firm continues the calendar into the measures that begin later. The 12.5 per cent production rate applies from the 2027 tax period, not 2026, so a manufacturer cannot claim it on current-year earnings and should plan its documentation in 2026 to be ready for the first qualifying period. The Istanbul Finance Center extension to 2047 took effect on publication, lengthening rather than delaying the existing benefit. The public-debt deferral changes — a deferral period raised from thirty-six to seventy-two months and an unsecured deferral ceiling raised to one million Turkish lira — took effect on publication and are immediately useful to a company managing an existing public liability while it restructures.
An Istanbul Law Firm uses the calendar to sequence client steps. Residency and the income exemption can be planned and, for those becoming resident in 2026, claimed for income from the start of that year; the wealth amnesty can be acted on now, with the early-declaration premium rewarding promptness; the corporate deductions require the 2026 bookkeeping to be correct for returns from July 2026; and the production rate is a 2027 matter to prepare for during 2026. A plan that respects these dates captures each benefit at the first lawful opportunity, while a plan that treats the package as a single switch thrown on 4 June 2026 will misfire on the measures that begin later. Practice may vary by authority and year, and each date should be reconfirmed against the implementing communiqués as they are issued.
Documentation: The Evidence Each Measure Requires
An English speaking lawyer in Turkey treats documentation as the core of the engagement rather than an afterthought, because each measure in Law No. 7582 places the burden of proof on the taxpayer. The twenty-year exemption requires contemporaneous evidence that the three calendar years before residence were clean: records of where the person was domiciled and resident in each year, evidence of the absence of disqualifying Turkish tax liability, and, where a prior Turkish source existed, proof that it fell within the protected passive categories. Building this file before residence is established is far easier than reconstructing it under examination years later.
A Turkish Law Firm sets out the parallel requirements for the wealth amnesty. A declaration must be supported by evidence of the existence and origin of the assets sufficient to satisfy source-of-funds verification, which in practice means bank statements over a reasonable historical period, tax filings or notarised declarations of legitimate acquisition, and business or inheritance documentation where relevant. Foreign assets must reach a Turkish account within two months, with the transfer documented, and physical imports substantiated through the Customs Administration. For the corporate deductions, the file is different again: an industrial registry certificate and production records for the 12.5 per cent rate, and, for the transit trade and qualified service centre deductions, evidence that the counterparties sit outside Turkey, that the earnings were repatriated by the return deadline, and that the qualifying conditions of the centre are met.
Turkish lawyers who handle cross-border matters add the authentication layer that foreign documents require. Foreign certificates, filings, and corporate records intended for use in Turkey generally need apostille authentication under the 1961 Hague Convention and sworn translation, and treaty benefits that interact with the exemption require a certificate of tax residence. None of this is exotic, but all of it takes time, and the difference between a client who assembled the file in advance and one who began after a query from the administration is usually the difference between a position that holds and one that is conceded. The documentary standard for each measure should be reconfirmed against the implementing communiqués once issued. Practice may vary by authority and year.
An Istanbul Law Firm adds a word on timing, because the order in which the file is built matters as much as its contents. For the income exemption, the cleanest position is one where the three-year evidence is gathered before Turkish residence is established, so that the record is contemporaneous rather than reconstructed; a person who waits until an enquiry arrives is assembling proof about years that have already passed, often from institutions abroad that respond slowly. For the wealth amnesty, the two-month repatriation clock starts at declaration, so the banking arrangements and the source-of-funds pack should be ready before the declaration is filed rather than after. For the corporate deductions, the 2026 bookkeeping has to be correct in real time, because the returns claiming the deductions fall due from July 2026 and a reconstruction after the fact invites challenge. In each case the discipline is the same: prepare the evidence ahead of the event that triggers the benefit, not after a question about it.
Who the 2026 Package Is Built For
An English speaking lawyer in Turkey finds eligibility analysis easier when the archetypes are clear, because the package rewards some profiles far more than others. The first is the returning member of the diaspora: a Turkish national who left long enough ago that the three calendar years before return carry no Turkish domicile and no disqualifying liability, and who now brings foreign income, foreign wealth, or both. For this client the income exemption, the one per cent inheritance rate, and the wealth amnesty often apply together, and the plan is essentially one of clean re-entry. The second is the foreign national with no Turkish tax history — a retiree, an investor, a remote professional, or an entrepreneur running a business abroad — for whom the income exemption converts a relocation into a long horizon of untaxed foreign income.
A Turkish Law Firm adds the corporate archetypes, because the package is not only for individuals. A multinational group managing service or intermediation functions for related parties across several countries is the intended user of the qualified service centre, able to house cross-border earnings at a near-zero effective rate, subject to the global minimum tax where the group is in scope. A trading group routing goods between third countries is the intended user of the transit trade deduction. A foreign-owned manufacturer with an industrial registry certificate is the intended user of the 12.5 per cent production rate from 2027. For each archetype the binding questions differ, but the method is the same: identify the measure that fits, confirm the statutory conditions, and document them in advance.
A lawyer in Turkey is candid about who the package does not transform. A multinational group above the global minimum tax threshold will often find the corporate incentives equalised back to fifteen per cent, so its decision rests on non-tax factors as much as on rate. An individual who cannot show a clean three-year history will not qualify for the income exemption regardless of how the relocation is framed, because the look-back is a statutory condition rather than a matter of presentation. Naming the misfit honestly at the outset saves a client from building a plan on a benefit that will not arrive. Practice may vary by authority and year.
Common Mistakes in Reading the 2026 Package
An Istanbul Law Firm sees the same errors repeatedly, and the most damaging is planning against the announcement rather than the statute. A client who fixes on the nine or fourteen per cent export rates, or on the full software-export exemption, is planning against figures that did not become law, and the disappointment is avoidable by reading Law No. 7582 rather than the April headlines. The second error is treating the One-Stop Office, the stabilisation clause, or the Terminal İstanbul project as enacted mechanisms on which a structure can rely; they are policy objectives, and a plan that depends on them depends on legislation that does not yet exist.
A Turkish Law Firm flags the date errors next. Assuming the whole package switched on with publication on 4 June 2026 misstates several measures: the production rate begins in 2027, the corporate deductions run through returns from July 2026 on 2026-period earnings, and the wealth amnesty rewards early rather than deadline-driven action. A client who claims a benefit in the wrong period invites assessment, and a client who waits assuming nothing begins until later forfeits the early-declaration premium on the amnesty. The third date error is forgetting that the income exemption reaches income from 1 January 2026 for those treated as resident, so a 2026 arrival is not too late for that year.
An English speaking lawyer in Turkey closes the list with the documentation error, which is the quietest and the most common. Each measure places the burden of proof on the taxpayer, and a benefit claimed without the contemporaneous file behind it is a benefit exposed on examination. The three-year history, the source-of-funds trail, the industrial registry certificate, the offshore counterparties, the repatriation records — none of these can be conjured after a query. The investor who treats the documentary file as part of the plan rather than a formality is the one whose position survives. Practice may vary by authority and year, and any reading of the package should be confirmed against the implementing communiqués once issued.
How a Turkish Law Firm Approaches the Package as a Whole
A lawyer in Turkey closes by situating the individual measures within a single relocation or investment plan, because they were designed to be used together rather than in isolation. A high-net-worth individual moving to Turkey typically combines the twenty-year income exemption, the one per cent inheritance rate, and the wealth amnesty, with residence or citizenship advice and real estate due diligence around them. A multinational group typically combines the qualified service centre or transit trade deduction with Istanbul Finance Center participation, read against the global minimum tax. A manufacturer combines the 12.5 per cent production rate with the existing export and production reductions. The value of integrated counsel is that the income plan, the wealth plan, the corporate plan, and the immigration plan are designed to fit together rather than pull against each other.
An Istanbul Law Firm treats the cluster of measures as a connected whole, and our materials are organised the same way. The twenty-year income exemption is covered in depth in our foreign income exemption guide; the wealth amnesty in our wealth amnesty guide; and the financial centre, its participants, and the qualified service centre regime in our Istanbul Finance Center hub. This page is the umbrella over those materials, and a foreign investor is best served by reading the relevant measure in detail once this overview has placed it in the structure of the whole package.
A Turkish Law Firm ends with the discipline that the package rewards. The enacted statute is more precise and in places more modest than the announcement, and the investor who plans against Law No. 7582 rather than the April headlines is the one who captures the benefits cleanly. That means using the enacted figures — twenty years, one per cent, five to zero per cent, ninety-five to one hundred per cent, 12.5 per cent, 2047 — rather than the figures that did not survive drafting, respecting the effective dates, and building the documentary file before it is needed. Done that way, the 2026 package is one of the more significant openings Turkish law has offered cross-border clients in a decade. Practice may vary by authority and year, and every element should be confirmed against current law and the forthcoming communiqués.
Author: Mirkan Topcu is an attorney registered with the Istanbul Bar Association (Istanbul 1st Bar), Bar Registration No: 67874. His practice focuses on cross-border and high-stakes matters where evidence discipline, procedural accuracy, and risk control are decisive, with particular concentration on foreign investor structuring under Law No. 7582, the twenty-year foreign income exemption under Mükerrer Article 20/D of the Income Tax Law, the one per cent inheritance rate under Article 16 of the Inheritance and Transfer Tax Law, the 2026 wealth amnesty under Provisional Article 19 of the Corporate Tax Law, the Istanbul Finance Center regime and the qualified service centre and transit trade deductions under Article 10 of the Corporate Tax Law, and the interaction of these measures with the global minimum tax. He advises individuals and companies across Immigration and Residency, Real Estate Law, Tax Law, Istanbul Finance Center participation, Foreign Investment, Commercial and Corporate Law, and cross-border documentation matters where procedural accuracy and evidence discipline are decisive.
He advises foreign investors and their advisors on the package as a connected whole: from eligibility analysis for the twenty-year exemption, with three-year non-residence documentation through residence certificates, foreign filings, and physical-presence evidence, through wealth amnesty preparation including source-of-funds documentation and repatriation mechanics, qualified service centre and Istanbul Finance Center structuring, production-rate analysis for foreign-owned manufacturers, and the global minimum tax computation for in-scope groups, to the assembly of the documentary file each measure requires and coordination across the income, wealth, corporate, and immigration plans. His practice spans Commercial and Corporate Law, Commercial Contracts, Foreign Investment, Data Protection and Privacy, Intellectual Property, Arbitration and Dispute Resolution, Enforcement and Insolvency, Citizenship and Immigration, Real Estate, International Tax, International Trade, Foreigners Law, Sports Law, Health Law, and Criminal Law.
Education: Istanbul University Faculty of Law (2018); Galatasaray University, LL.M. (2022). LinkedIn: Profile. Istanbul Bar Association: Official website.
Frequently asked questions
- Is the 2026 foreign investor tax package now law? The operative parts are. Law No. 7582 was accepted by the Grand National Assembly on 21 May 2026 and published in the Official Gazette No. 33270 on 4 June 2026, entering into force on publication except where a later date is specified. It enacts the twenty-year income exemption, the one per cent inheritance rate, the wealth amnesty, the Istanbul Finance Center extension, the transit trade and qualified service centre deductions, and the production rate, among other measures. Several items from the April announcement, however, were not enacted in this statute.
- What is the relationship between the April announcement and Law No. 7582? The 24 April 2026 programme was a political framework; Law No. 7582 is the enforceable statute. The statute enacted some announced measures faithfully, reshaped others during drafting, and left some as policy intentions. A foreign investor should plan against the enacted text rather than the announcement, because several headline figures changed or did not pass.
- Did the corporate tax rate fall to nine per cent for exporters? No. The nine per cent manufacturer-exporter and fourteen per cent other-exporter rates from the announcement were not legislated in that form. What Law No. 7582 enacted is a 12.5 per cent rate on the production earnings of companies holding an industrial registry certificate and actually engaged in production, applying from the 2027 tax period. The general corporate rate remains twenty-five per cent, with the pre-existing export and production reductions unchanged.
- What is the twenty-year foreign income exemption? Under the new Mükerrer Article 20/D of the Income Tax Law, a person who becomes a Turkish tax resident, and who in the three calendar years before becoming resident had neither a domicile nor a tax liability in Turkey, may keep foreign-source income outside the Turkish tax base for twenty years. It applies to income derived from 1 January 2026 by those treated as resident. The full mechanics are in our dedicated twenty-year exemption guide.
- What is the one per cent inheritance rate? Law No. 7582 amended Article 16 of the Inheritance and Transfer Tax Law so that, for a person benefiting from the Article 20/D exemption, transfers by inheritance within the exemption period are taxed at one per cent, against an ordinary progressive scale that rises into double digits on larger estates. It is a companion benefit to the income exemption and is tied to the same qualification.
- What is the 2026 wealth amnesty and what does it cost? Under Provisional Article 19 of the Corporate Tax Law, real and legal persons may declare money, gold, foreign currency, securities, and other capital market instruments held abroad or unrecorded in Turkey by 31 July 2027. The rate runs from five per cent down to zero according to a one-to-five-year holding commitment in qualifying instruments, with a half-point added in an early window and a point in any extension. Real estate is outside scope. Our wealth amnesty guide sets out the detail.
- Did the software and engineering export exemption rise to one hundred per cent? Not under Law No. 7582. The export-services deduction for software, engineering, architecture, and design exists under the Income Tax Law and Corporate Tax Law and currently stands at eighty per cent following a 2023 amendment. The announced increase to one hundred per cent is not among the articles of Law No. 7582 and should not be treated as enacted.
- What changed for the Istanbul Finance Center? Law No. 7582 extended the core incentive horizon from 2031 to 2047 and adjusted the related period reference from five to twenty years. It also created, under Article 10 of the Corporate Tax Law, a transit trade deduction and a qualified service centre deduction of ninety-five per cent, rising to one hundred per cent inside the centre or approved industrial zones. The qualified service centre is defined in the Foreign Direct Investment Law.
- What is a qualified service centre? It is a new category defined by Law No. 7582 in the Foreign Direct Investment Law for entities that earn predominantly from related parties across several countries. A qualified service centre may deduct ninety-five per cent of its qualifying foreign-source earnings, rising to one hundred per cent inside the Istanbul Finance Center or approved zones, for twenty accounting periods. It is the enacted vehicle closest to what the announcement called a regional headquarters incentive.
- How does the global minimum tax affect these incentives? Turkey enacted the local and global minimum complementary corporate tax through Law No. 7524 (Official Gazette 2 August 2024), targeting groups with consolidated revenue of 750 million euro or more at a fifteen per cent floor. For an in-scope group, a low Turkish effective rate produced by the package's deductions can be topped up to fifteen per cent. Groups below the threshold take the full benefit; in-scope groups should model the incentives against the floor.
- Was the One-Stop Office enacted? The broad investor-wide One-Stop Office described in April is a programme objective rather than a new statutory mechanism in Law No. 7582. A one-stop arrangement already exists within the Istanbul Finance Center under its own legislation, coordinated by the Presidency's Finance Office, but the wider office is not legislated in this statute.
- When do the different measures take effect? The income exemption and one per cent inheritance rate took effect on publication, with the exemption reaching income from 1 January 2026 for those treated as resident. The transit trade and qualified service centre deductions apply to 2026-period earnings in returns from 1 July 2026. The production rate applies from the 2027 tax period. The Istanbul Finance Center extension and the public-debt deferral changes took effect on publication.
- Can I still benefit if I become resident in 2026? Yes. The income exemption reaches income derived from 1 January 2026 by those treated as resident, so a 2026 arrival is not too late for that year, provided the three-year look-back before residence is clean. The eligibility analysis turns on domicile and tax liability in the three preceding calendar years, not on the timing within 2026.
- What documentation will I need? Each measure places the burden of proof on the taxpayer. The income exemption needs evidence of a clean three-year history; the wealth amnesty needs source-of-funds documentation and repatriation records; the production rate needs an industrial registry certificate and production records; the transit trade and qualified service centre deductions need evidence of offshore counterparties, timely repatriation, and the qualifying conditions. Foreign documents generally need apostille authentication and sworn translation.
- How does ER&GUN&ER Law Firm advise on the 2026 package? We work from the enacted statute rather than the announcement, identify the measures that fit a client's profile, confirm the statutory conditions, and build the documentary file each measure requires. For individuals that usually means the income exemption, the one per cent inheritance rate, and the wealth amnesty together; for companies it means the qualified service centre or transit trade deduction and the production rate, read against the global minimum tax. We coordinate the income, wealth, corporate, and immigration plans so they fit together, and we reconfirm each position against the implementing communiqués as they are issued.