New Development
With Law No. 7582 on the Amendments to Certain Laws (the “Law”), published in the Official Gazette dated 4 June 2026, amendments have been made to the Foreign Direct Investment Law No. 4875 (the “Foreign Direct Investment Law”) and the Corporate Tax Law No. 5520 (the “Corporate Income Tax Law”), introducing regulations concerning the Qualified Service Center (“QSC”) regime (the “Amendment”). Accordingly, it is aimed that these comprehensive reforms, envisaged to strengthen the investment environment and enhance Türkiye’s international competitiveness, will give rise to significant legal outcomes.
Through the Amendment, the QSC regime has been defined; certain harmonization changes have also been introduced to the existing Istanbul Financial Center (“IFC”) incentive regime in respect of QSCs operating within the IFC, and significant tax incentives have been provided to QSCs by amending Article 10 of the Corporate Income Tax Law, which regulates deductions to be made from the corporate tax base.
In this bulletin, the key amendments introduced under the Foreign Direct Investment Law specifically regarding QSCs are summarized. For our explanations regarding the corporate tax deduction and wage exemption granted to qualified personnel, is available here “Türkiye’s New Tax and Investment Reform Package: Key Highlights” published on 22 May 2026 (the “Bulletin”).
Definition of Qualified Service Centers
The QSC regime became effectively applicable as of the date the Law entered into force upon its publication in the Official Gazette. Within the scope of the Amendment, pursuant to Additional Article 1 added to the Foreign Direct Investment Law, a QSC is defined as a capital company established to provide the below services to related companies or a group of companies actively operating in at least three different countries and deriving at least 80% of its annual revenue from related parties abroad.
Under the regulation, the services that may be provided by QSCs include: financial consultancy, strategic management consultancy, 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 consultancy, investment and data analysis, legal consultancy (provided that legal consultancy regarding domestic activities or Turkish law is procured solely from attorneys or attorney partnerships authorized under the Attorneyship Law No. 1136 dated 19 March 1969), promotion, brand management, human resources and training services, as well as coordination and management services related to these activities. These also include coordination and management services in relation to sales, after-sales support, technical support, research and development, outsourcing, testing of newly developed products, and laboratory services.
Additionally, under the Amendment, employees who directly perform the aforementioned services, excluding support personnel, are defined as qualified service personnel.
The Amendment specifies that the Ministry of Industry and Technology is authorized to regulate the activities of QSCs, subject to obtaining the opinions of the Ministry of Treasury and Finance and the Ministry of Trade.
Advantages Provided to Qualified Service Centers
With respect to corporations operating as QSCs under the Foreign Direct Investment Law, subparagraph (i) of the first paragraph of Article 10 of the Corporate Income Tax Law has been amended and a new subparagraph has been added as follows:
- “i) 95% of the income derived from the sale of goods purchased abroad without being brought into Türkiye or from intermediary activities related to the purchase and sale of goods abroad (this rate is applied as 100% for corporations operating in industrial zones established under the Industrial Zones Law No. 4737, as deemed appropriate by the President based on foreign investment intensity, and for corporations operating in the Istanbul Financial Center Region with a participant certificate under Law No. 7412).
To benefit from this deduction, the income must be transferred to Türkiye by the deadline for filing the annual corporate tax return for the relevant fiscal period, and both the buyer and seller of the goods subject to intermediary activities must not be located in Türkiye. The President is authorized to decrease or increase these rates down to 0% or up to 100%.”
- “j) 95% of the income derived exclusively from activities carried out abroad by corporations operating as qualified service centers within the scope of the Foreign Direct Investment Law (this rate is applied as 100% for corporations operating in industrial zones deemed appropriate by the President based on foreign investment intensity and for QSCs operating in the Istanbul Financial Center Region with a participant certificate under Law No. 7412).
This deduction is applied for twenty fiscal periods starting from the fiscal period in which the QSC becomes operational, provided that the income is transferred to Türkiye by the deadline for filing the annual corporate tax return for the relevant period. The President is authorized to decrease this rate down to 50% or increase it up to 100%.”
For a detailed evaluation of the tax advantages granted to QSCs, you may refer to our Bulletin.
Conclusion
The QSC regime introduced by the Amendment stands out as one of Türkiye’s strategic steps to improve its international investment environment. In this way, a concrete framework has been established to encourage multinational companies to position their regional management and service activities in Türkiye.
When these regulations are considered from a holistic perspective, it is observed that a comprehensive economic policy approach has been adopted with the aim of enhancing Türkiye’s competitiveness in international investment, finance, technology, and service sectors. In particular, the linkage established with the IFC and the structure centered around a qualified workforce contribute to positioning Türkiye not only as a production hub but also as a management and service center.
Within this framework, it is expected that the QSC regulations will have a decisive impact on companies’ organizational structures and investment strategies in the coming period and will further strengthen Türkiye’s goal of becoming a regional hub.
Considering that, under the amendment to the Foreign Direct Investment Law, the Ministry of Industry and Technology is authorized, by being subject to the opinions of the Ministry of Treasury and Finance and the Ministry of Trade, possible secondary legislation should also be closely monitored.
