Article 1: The phrase '36' in the first paragraph of Article 48 of the Law on the Collection Procedure of Public Receivables No. 6183 dated 21/7/1953 has been changed to '72', and the phrases 'fifty thousand New Turkish Lira' in the second paragraph have been changed to 'one million Turkish Lira'.
Article 2: An additional paragraph has been added to Article 16 of the Inheritance and Transfer Tax Law No. 7338 dated 8/6/1959, to come after the second paragraph. 'For those benefiting from the income tax exemption under the repeated Article 20/D of the Income Tax Law No. 193 dated 31/12/1960, the tax rate on the inheritance of property occurring within the period specified for the said exemption is applied at 1%.'
Article 3: The phrase 'amount' in the first paragraph of Article 17 of the Income Tax Law No. 193 dated 31/12/1960 has been changed to 'twice the amount', and the phrases 'three', 'four', 'six', 'seven', and 'twelve' in the second paragraph have been changed to 'two', 'three', 'four', 'five', and 'six', respectively.
Article 4: The following article has been added after the repeated Article 20/C of Law No. 193. 'Tax exemption for income and revenues obtained from abroad: REPEATED ARTICLE 20/D- Real persons deemed to be resident in Turkey, provided that they do not have a residence and tax liability in Turkey in the last three calendar years before being deemed resident in Turkey, are exempt from income tax for twenty years on income and revenues obtained from abroad. The existence of tax liability due to real estate capital income, movable capital income, or capital gains obtained in Turkey before entering the scope of this article does not prevent these real persons from benefiting from this exemption. No annual declaration is required for the income and revenues within the scope of the first paragraph, and if a declaration is made for other income, these incomes are not included in the declaration. Expenses and costs related to the income and revenues within the scope of the exemption are not taken into account in determining taxable income and revenues. Taxes paid in foreign countries due to income and revenues within the scope of this exemption cannot be deducted from the income tax assessed in Turkey. If it is later determined that the conditions for the exemption are not met, the taxes not accrued are deemed to have been lost. The Ministry of Treasury and Finance is authorized to determine the procedures and principles regarding the implementation of this article.'
Article 5: The following clause has been added to the first paragraph of Article 23 of Law No. 193. '20. The portion of the salaries of qualified service personnel employed in qualified service centers defined in the additional Article 1 of the Direct Foreign Investments Law No. 4875 dated 5/6/2003, which does not exceed three times the gross minimum wage (for industrial zones established under the Industrial Zones Law No. 4737 dated 9/1/2002, as determined by the President according to the foreign investment density of the region, and for qualified service centers operating in the Istanbul Finance Center with a participant certificate, the gross minimum wage is applied as five times.). The President is authorized to determine the three and five times mentioned in this clause together or separately, and to increase it up to two times.'
Article 6: The following additional article has been added to the Direct Foreign Investments Law No. 4875 dated 5/6/2003. 'Qualified service center ADDITIONAL ARTICLE 1- A qualified service center refers to capital companies that are established to provide services to related companies or corporate groups and to carry out the activities specified in the second paragraph, actively operating in at least three different countries, and obtaining at least 80% of their annual revenues from related companies or corporate groups abroad. These centers provide: a) 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 related to domestic activities or Turkish law can only be provided by lawyers or law partnerships that can provide services under the Law No. 1136 dated 19/3/1969), promotion, brand management, human resources and training services, and coordination and management services related to these services, 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. Employees who directly perform the services within the scope of the second paragraph, excluding support personnel, are qualified service personnel. The Ministry of Industry and Technology is authorized to determine the procedures and principles regarding the implementation of this article by obtaining the opinions of the Ministry of Treasury and Finance and the Ministry of Commerce.'
Article 7: The (i) subparagraph of the first paragraph of Article 10 of the Corporate Tax Law No. 5520 dated 13/6/2006 has been amended as follows and the following subparagraph has been added to the paragraph. 'i) 95% of the income obtained from the sale of goods purchased from abroad without bringing them to Turkey or from the intermediation of transactions conducted abroad (for industrial zones established under the Industrial Zones Law No. 4737 dated 9/1/2002, the rate is applied as 100% for institutions operating in the Istanbul Finance Center Region with a participant certificate, as determined by the President according to the foreign investment density of the region and under the provisions of the Istanbul Finance Center Law No. 7412 dated 22/6/2022.). To benefit from this discount, it is required that the income be transferred to Turkey by the deadline for submitting the annual corporate tax return for the accounting period in which the income is obtained, and that neither the seller nor the buyer of the goods related to the intermediation activity is in Turkey. The President is authorized to reduce the rates mentioned in this subparagraph to zero and to increase them up to 100%.'
j) For institutions operating as qualified service centers under the Direct Foreign Investments Law No. 4875 dated 5/6/2003, 95% of the income obtained from abroad exclusively within the scope of these activities (for institutions operating as qualified service centers in the Istanbul Finance Center Region with a participant certificate under the provisions of the Law No. 7412, the rate is applied as 100% according to the foreign investment density of the region.). This discount is applied for twenty accounting periods starting from the accounting period in which the qualified service center commenced operations, provided that the income is transferred to Turkey by the deadline for submitting the annual corporate tax return for the accounting period in which the income is obtained. The President is authorized to reduce the rates mentioned in this subparagraph up to 50% and to increase them up to 100%.
Article 8: The eighth paragraph of Article 32 of Law No. 5520 has been amended as follows. '(8) The corporate tax rate shall be applied at 12.5% for the profits obtained exclusively from the production activities of institutions holding an industrial registry certificate and engaged in actual production activities, and for the profits obtained exclusively from the agricultural production activities of institutions engaged in agricultural production activities. No additional discount shall be applied to the profits benefiting from the reduced rate under this paragraph according to the seventh paragraph.'
Article 9: The phrase '(g) and (h)' in the (b) subparagraph of the second paragraph of Article 32/C of Law No. 5520 has been changed to '(g), (h), (i) and (j)' and the following subparagraph has been added to the paragraph. 'd) The income discount mentioned in the (a) subparagraph of the first paragraph of Article 6 of Law No. 7412.'
Article 10: The following temporary article has been added to Law No. 5520. 'TEMPORARY ARTICLE 19- (1) In order to increase voluntary compliance with taxes, real or legal persons shall declare their assets located abroad; cash, gold, foreign currency, securities, and other capital market instruments to banks or intermediaries until 31/7/2027. (2) The assets declared under the first paragraph must be transferred to accounts opened in their names at banks or intermediaries in Turkey within two months from the date of declaration, or those physically brought from abroad must be deposited into these accounts. The physical presence of the assets brought from abroad in Turkey shall be evidenced by documents related to the declaration to the Customs Administration. The Customs Administration shall report the declarations received in this context to the Revenue Administration by the end of the month following the month in which they were received. (3) Cash, gold, foreign currency, securities, and other capital market instruments owned by income or corporate tax taxpayers and located in Turkey but not recorded in legal books must be declared to banks or intermediaries until 31/7/2027. It is mandatory to prove the declaration of the declared assets by depositing them into banks or intermediaries as of the date of declaration. (4) The declared assets under the first and third paragraphs shall be recorded in the legal books by taxpayers who keep books according to the Law No. 213 as of the date of declaration. Taxpayers keeping books according to the balance sheet principle shall open a special fund account in the liabilities for the values they record in their legal books under the provisions of this article. This fund account cannot be withdrawn from the business for two years from the date of declaration, cannot be used for any purpose other than adding to the capital, and shall not be taxed in case of liquidation of the business. Taxpayers keeping a freelance income ledger and those keeping books according to the business account principle shall also show these values separately in their books. These assets shall not be taken into account in determining the period profit and may be withdrawn from the business without being taken into account in determining taxable income and distributable income for corporations, provided that two years have passed from the date of declaration. (5) Those without income and corporate tax liability may benefit from the provisions of this article without the conditions specified in the fourth paragraph, provided they bring the declared assets to Turkey within the period specified in the second paragraph and prove their domestic assets by depositing them into banks or intermediaries as of the date of declaration. (6) Banks and intermediaries shall declare the tax they collect in advance at the rate of 5% on the value of the declared assets from the declarant, by the evening of the fifteenth day of the month following the declaration, as a tax responsible person, with a declaration to the relevant tax office. However, the tax rate shall be applied as 0% if it is committed that the declared asset will be held in time deposits, state domestic borrowing securities issued under the Law No. 4749, or lease certificates for at least five years; 1% if it is committed for at least four years; 2% if it is committed for at least three years; 3% if it is committed for at least two years; and 4% if it is committed for at least one year. For declarations made between 1/1/2027 and 31/7/2027 (inclusive), an increase of half a point will be made to these rates. In the event of an extension of the date of 31/7/2027, the tax rate will be applied with an additional increase of half a point, totaling a 1-point increase for declarations made after this date. No stamp tax shall be collected from the declarations to be given under this paragraph. (7) The tax paid under this article cannot be deducted as an expense in any way and cannot be offset against another tax. Losses arising from the disposal of the declared assets shall not be considered as expenses or deductions for income or corporate tax purposes. (8) No tax audit or tax assessment shall be conducted regarding the amounts corresponding to the declared assets in any way. However, measures that must be taken under other legislation shall not be affected by this regulation. In cases where tax audits initiated for other reasons or the determination of the tax commission result in a tax base difference arising from the declared assets, and if the amount of the declared assets is equal to or greater than the determined tax base difference, no taxation shall be made regarding the tax base difference. If the tax base difference is greater than the amounts declared, only tax assessment shall be made on the difference amount. In cases where a tax base difference is determined for reasons other than the declared assets as a result of tax audits or tax commission decisions, the amounts declared under this article shall be taxed without being offset against the determined tax base difference. (9) If the declared assets are not brought to Turkey within two months from the date of declaration, or not transferred to accounts to be opened at banks or intermediaries in Turkey, or not deposited into banks or intermediaries within the period specified in the same paragraph, the taxes assessed on the declared amounts shall not benefit from the provisions of the eighth paragraph. In addition, taxes that are not accrued on time shall be collected together with late interest without applying tax loss penalties. The provisions of the eighth paragraph shall not apply to tax assessments to be made as a result of the declaration made under this article after the date on which the tax audit is initiated or referred to the tax commission. The non-payment of the accrued tax on time does not prevent the collection and follow-up of the tax principal together with the delay penalty under the Law No. 6183. Taxes collected shall not be refunded or returned. (10) No corrections can be made to the declarations after the declaration period has expired. (11) The President may extend the date of 31/7/2027 for up to one year in periods not exceeding six months from the end date; the Ministry of Treasury and Finance is authorized to determine the matters regarding the transfer and declaration of the assets covered by this article to Turkey and their inclusion in the business, the form of declaration and notification, the information and documents to be used in the implementation of the article, and the procedures and principles regarding the implementation.'
Article 11: The provisions of this Law shall be executed by the President.
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