Qualified Service Centres in Türkiye: Which Companies and Employees Qualify for Wage Tax Relief?

What has actually changed?

The new schedule announced on 2 November 2026 for the annexes to Türkiye's Combined Withholding Tax and Social Security Premium Return (MUHSGK) may appear to introduce a broad new ‘qualified employment incentive’. In fact, it concerns a narrowly defined income-tax exemption for the remuneration of eligible personnel directly delivering specified services at qualifying international service centres. The new schedule provides a way of reporting a relief that already exists.

The legal foundation is Article 5 of Law No. 7582, published in Official Gazette No. 33270 on 4 June 2026, which inserted subparagraph (20) into Article 23(1) of the Income Tax Law. Article 6 of the same law added Supplementary Article 1 to Foreign Direct Investment Law No. 4875, defining both a ‘qualified service centre’ and ‘qualified service personnel’.

Income Tax General Communiqué Series No. 334, published on 4 July 2026, explains how the payroll exemption works. The MUHSGK update of 2 November 2026 adds a disclosure schedule; it does not create a new tax exemption.

Which companies qualify as service centres?

Supplementary Article 1 of Law No. 4875 describes a qualified service centre as a capital company established to provide specified services to related companies or a group of companies that actively operate in at least three different countries. At least 80% of the centre's annual revenue must be generated from related companies or group companies located abroad.

The test focuses on the international activity of the related companies or group receiving the services: it does not simply require the Turkish company itself to open branches in three countries. The actual ownership, control and related-party relationship should be evidenced.

An individual sole practitioner or a Turkish service exporter with independent overseas customers does not qualify solely because the exporter is successful internationally. The corporate form, group structure, sources of revenue and statutory service categories must all be examined.

Which activities are expressly listed in the legislation?

Supplementary Article 1 distinguishes services that may be provided directly from the coordination and management of certain operational functions. This matters especially for software engineering, sales and technical support: the exact description of the work is relevant.

• Financial consulting; strategic management consulting; risk management; cash and liquidity management; funding and borrowing; investment and capital-structure planning; budgeting.
• Financial reporting and analysis; international accounting and compliance; audit; investment and data analysis.
• Digital transformation and technology consulting; promotion and brand management; human resources and training, as well as the coordination and management of these services.
• Coordination and management of sales, after-sales support, technical support, research and development, external procurement, testing of new products and laboratory services.

Which employees may be qualified service personnel?

Under Law No. 4875, qualified service personnel are those who directly perform the services listed in Supplementary Article 1(2), excluding support personnel. The statute does not grant relief merely because someone has a university degree, uses a particular occupational code, speaks another language or receives a high salary.

The following examples are indicative only. The actual job description, work performed, recipient group company and deliverables must be reviewed for each employee.

How should accountants, CPAs, software and HR professionals be assessed?

An accountant working at a Turkish service centre may qualify by directly performing consolidation, financial reporting or international accounting compliance for overseas companies in an eligible multinational group. Simply maintaining the Turkish company's ordinary statutory books does not, by itself, establish that the services meet the international-centre definition.

Likewise, an ERP transformation adviser providing technology consulting to related group companies is not in the same position as a developer delivering software products to independent customers. The legislation refers expressly to digital transformation and technology consulting, but it does not mean every software developer or R&D employee automatically qualifies.

Human resources, training, brand management and related coordination may themselves be qualifying services. The exclusion of ‘support personnel’ should not be confused with excluding every HR specialist. Job descriptions, intercompany agreements, project outputs and actual services matter more than the title printed on a business card.

Illustrative examples: three-country group and 80% revenue test

Example A: A Turkish limited company provides financial reporting and HR services to related companies in a group actively operating in Germany, the Netherlands, Türkiye and Poland. Of TRY 20 million in annual revenue, TRY 17 million is billed to qualifying related companies abroad and TRY 3 million to other customers. The overseas related-party share is 85%. If the services and personnel meet the remaining conditions, the company may be assessed positively as a qualified service centre.

Example B: A Turkish software business derives 95% of revenue from several independent US customers but has no related-company group actively operating in three countries. An impressive export ratio alone does not satisfy the statutory definition.

Example C: Even an eligible centre does not qualify every employee. An analyst directly providing group financial-analysis services may qualify, whereas a general office driver remains excluded as support staff.

How much remuneration is exempt in 2026?

The gross monthly minimum wage for 2026 is TRY 33,030. Accordingly, the ordinary ceiling for income-tax-exempt gross remuneration is TRY 99,090 per month (three times the gross minimum wage). For centres meeting the additional statutory requirements in qualifying designated industrial zones or operating in the Istanbul Financial Center with a participation certificate, the ceiling is TRY 165,150 (five times the gross minimum wage).

The exemption applies only to the qualifying portion of the employee's remuneration. Any amount exceeding the applicable ceiling is assessed under the ordinary income-tax rules. Salary may include bonuses, overtime and other benefits recognised as remuneration under the Income Tax Law.

The portion exempt under Income Tax Law Article 23(1)(20) is also exempt from stamp duty under Article 5(3) of Income Tax General Communiqué No. 334. The amount exceeding the statutory ceiling remains subject to ordinary income-tax and stamp-duty rules. This relief does not waive social security or unemployment insurance contributions, which must be calculated separately.

How should the three examples in Communiqué No. 334 be read?

In Example 1 of the Communiqué, an eligible employee earns TRY 90,000 gross per month in November 2026. The pay is below the ordinary TRY 99,090 ceiling, so the entire gross remuneration is within the income-tax exemption; social security deductions are calculated separately.

In Example 2, gross monthly pay is TRY 200,000. The portion exceeding TRY 99,090 falls under the normal tax rules. Tax Law Articles 31 and 63, the graduated income-tax tariff and the minimum-wage relief under Article 23(1)(18) must be considered together. Calculating net pay by simply applying a flat rate to TRY 200,000 minus TRY 99,090 would be unreliable.

In Example 3, an eligible employee working at a qualifying Istanbul Financial Center centre with the required participation certificate earns TRY 150,000 gross in August 2026. As this is below the TRY 165,150 enhanced ceiling, the entire gross remuneration falls within the income-tax exemption. Being merely located somewhere in Istanbul does not establish IFM eligibility.

What changed in MUHSGK reporting for October 2026?

According to the Digital Tax Office notice dated 2 November 2026, a new schedule titled ‘Notification of the Wage Exemption for Qualified Service Personnel Employed at Qualified Service Centres (Income Tax Law Article 23/20)’ was added to the annexes of the combined withholding and social security premium return, beginning with the October 2026 tax period for returns submitted from 1 November 2026.

The schedule asks for workplace province, district and tax office, the number of eligible employees, the social security workplace registration number and address. For each worker it asks for name, Turkish ID number, starting date, gross pay, exempt remuneration base, taxable remuneration base and income tax withheld.

Taxpayers using the e-Beyanname application should update the Return Preparation Program (BDP) via Digital Tax Office > Required Programs. The new fields do not make all employers eligible for the relief; they are intended to identify beneficiaries already meeting the legal conditions.

When populating the exempt and taxable wage-base fields, the payroll computation under Communiqué No. 334 and the form instructions should be reconciled. The minimum-wage relief, stamp duty and social-security contributions must not be treated as interchangeable deductions.

• Verify the workplace location, tax office, SGK registration and address.
• Reconcile eligible headcount with personnel and payroll records.
• Confirm each employee's start date, actual role, gross pay and ceiling.
• Reconcile the exempt and taxable remuneration bases.
• Update the BDP software and complete the relevant MUHSGK annex.
• Reconcile reported tax to the payroll and relevant stamp-duty calculations.

Is there a separate corporate income-tax benefit?

Yes. Law No. 7582 also introduced paragraph (j) to Article 10(1) of the Corporate Tax Law. Subject to the separate statutory conditions, eligible qualified service centres may deduct 95% of qualifying profits derived exclusively from their covered services supplied abroad. The rate is 100% for qualifying centres in the specially designated industrial zones or Istanbul Financial Center under the applicable conditions.

The relief applies for up to 20 accounting periods from the period in which the centre began operations. Qualifying profits must be transferred to Türkiye no later than the due date for the annual corporate income-tax return for the period concerned, along with the other legal conditions.

The 95% or 100% is a deduction relating to eligible profit, not gross turnover. The corporate deduction and employee wage exemption must be examined separately: qualifying for one does not automatically prove eligibility for the other.

A practical documentation and control checklist for accounting professionals

The main compliance risk is claiming that ‘the first three minimum wages are tax free’ without testing the company's international group, qualifying revenue and the actual services of its staff. An incorrectly claimed exemption may lead to additional withholding, stamp-duty exposures where applicable, interest and penalties.

For the entity, examine trade registry records, the countries of activity of related companies, ownership/control ties, intercompany service agreements, overseas related-party invoices and annual turnover calculations.

For personnel, document job duties, overseas recipient companies, project or reporting outputs, employment terms, payroll components and separation from excluded general support functions. Where the enhanced ceiling is sought, verify the relevant official industrial-zone status or IFM participation certificate.

Law No. 4875 authorises the Ministry of Industry and Technology to establish implementing procedures after consulting the Treasury and Finance and Trade Ministries. Any applicable subsequent procedures should be checked before a specific application or tax position is finalised.

Conclusion: a conditional international service-centre relief, not a general high-skill incentive

The purpose of Article 23(1)(20) is to provide income-tax relief for eligible personnel who directly deliver specified services at international group service centres meeting the corporate tests. The employer's status and the employee's actual duties must therefore be established together.

Degrees, foreign-language ability, high salaries and titles such as finance director or software engineer are not sufficient on their own. Conversely, genuinely providing international accounting, financial analytics or technology consulting to eligible related group companies may support an assessment where the employer also qualifies.

This article reflects the legislation and regulatory material available as of 5 November 2026, including Law No. 7582, Law No. 4875 Supplementary Article 1, Income Tax Law Article 23(1)(20), Communiqué No. 334 and the MUHSGK notification dated 2 November 2026. The specific facts, official documentation and later regulations should always be checked.