Omnibus Law No. 7582: New Tax Rules for Foreign Investors and New Residents in Türkiye

General Framework of Omnibus Law No. 7582

Law No. 7582 is a tax and investment package consisting of fifteen articles and amending six separate laws. An omnibus law is defined as a law that gathers provisions on a range of different subjects within a single text. The principal pieces of legislation amended by this text are: the Law on the Procedure for the Collection of Public Receivables (No. 6183), the Income Tax Law (No. 193), the Inheritance and Transfer Tax Law (No. 7338), the Foreign Direct Investment Law (No. 4875), the Corporate Tax Law (No. 5520), the Law on the Support of Research, Development and Design Activities (No. 5746) and the Istanbul Finance Centre Law (No. 7412).

Foreign property owners living in Antalya, individuals planning to relocate to Türkiye and companies engaged in international activity are each affected by this package in different ways. The table below summarises the articles of the law by subject.

Provisions Concerning Individual Taxpayers

For natural persons, the most notable innovations of the law are the income tax exemption directed at those newly settling in Türkiye and the related inheritance tax advantage. These provisions produce direct consequences in particular for individuals with international income and for foreign nationals planning to establish residence in Türkiye.

Twenty-Year Income Tax Exemption on Foreign Earnings (Article 4)

Repeating Article 20/D, added to the Income Tax Law by Article 4 of the law, exempts the foreign earnings of natural persons newly settling in Türkiye from income tax for a period of twenty years. The exemption is directed at persons who, in the three calendar years preceding the year in which they are deemed settled in Türkiye, had no domicile and no tax liability in Türkiye. The scope is limited to earnings and revenues derived outside Türkiye; Türkiye-source income remains subject to general rules.

Income Tax Law, Repeating Article 20/D (unofficial translation)

"The earnings and revenues that natural persons deemed settled in Türkiye derive outside Türkiye are exempt from income tax for twenty years, on condition that they had no domicile and no tax liability in Türkiye during the last three calendar years prior to being deemed settled in Türkiye."

No annual return is filed for the earnings and revenues within the scope of the exemption. Even where the person is required to file a return on account of other income, the foreign income within the scope of the exemption is not included in that return. Pursuant to Article 4, this provision entered into force to apply to those acquiring tax residence in Türkiye as of 1 January 2026.

One Percent Rate on Inheritance and Transfer Tax (Article 2)

Article 2 of the law provides a reduced rate for those benefiting from the income tax exemption above, in respect of transfer of property by inheritance. For transfer of property by inheritance taking place within the period foreseen for the exemption, the tax rate is applied as one percent.

Inheritance and transfer tax is defined as a tax levied where assets are acquired through gratuitous means such as death or gift. While rates in the general tariff increase progressively according to the value of the assets, a fixed one percent rate applies for persons within the scope of this provision in respect of transfers occurring within the period. In this respect, the provision constitutes a notable advantage for foreign investors engaged in estate planning.

Law No. 7582, Article 2 (unofficial translation)

"For those benefiting from the income tax exemption under Repeating Article 20/D of Income Tax Law No. 193, the tax rate is applied as 1% for transfer of property by inheritance taking place within the period foreseen for the said exemption."

Wage Exemption for Qualified Service Centre Personnel (Article 5)

Article 5 of the law adds a new paragraph to Article 23 of the Income Tax Law, providing an exemption for the wages of personnel employed in qualified service centres. Accordingly, the portion of such personnel's wages not exceeding three times the gross minimum wage is exempt from income tax. For those working in the Istanbul Finance Centre and certain industrial zones, this limit is applied as five times the gross minimum wage. The President is authorised to amend these multipliers within certain limits.

Foreign Asset Declaration (Article 10)

Provisional Article 19, added to the Income Tax Law by Article 10 of the law, allows money, gold, foreign currency and securities held abroad to be declared to Türkiye. The deadline for declaration is set as 31 July 2027. The purpose of the practice is to increase voluntary tax compliance and to encourage the integration of assets held abroad into the economy.

As a rule, tax is paid at a rate of five percent in advance on declared assets. However, depending on the period for which the asset is held in Türkiye, this rate decreases on a graduated basis; where the asset is held for a period of five years, the rate may fall as low as zero percent. With respect to the amounts corresponding to declared assets, no tax inspection and no tax assessment is carried out under any circumstances.

Tax Rates by Holding Period

Provisions Concerning Corporations and Investors

In the area of corporate tax, the law introduces a series of reductions encouraging international trade, service exports and production activities. These provisions carry significance for companies based in Antalya that conduct cross-border transactions and for investors establishing international structures.

Reduction on Foreign Trade and Service Earnings (Article 7)

Article 7 of the law provides reductions for two distinct types of earnings under the Corporate Tax Law. Ninety-five percent of the earnings derived from selling goods purchased abroad outside Türkiye without bringing them into Türkiye, or from acting as an intermediary in the purchase and sale of goods occurring abroad, may be deducted from corporate tax. For the Istanbul Finance Centre and certain industrial zones, this rate rises to one hundred percent.

Secondly, ninety-five percent of the earnings that corporations operating as qualified service centres derive from abroad exclusively within the scope of these activities (one hundred percent in restricted zones) may be deducted from corporate tax for twenty accounting periods. These provisions apply to returns to be filed as of 1 July 2026 and to earnings derived as of 1 January 2026.

Definition of Qualified Service Centre (Article 6)

Article 6 of the law adds the definition of "qualified service centre" to the Foreign Direct Investment Law. A qualified service centre is defined as an entity that operates actively in at least three different countries, derives a significant part of its annual revenue from related companies abroad, and provides those companies with services such as financial advisory, risk management, legal advisory, human resources, sales support, research and development, and coordination. This definition is the core criterion determining to whom the incentives in Articles 5 and 7 apply.

12.5% Rate on Manufacturing and Agricultural Production Earnings (Article 8)

Article 8 of the law amends Article 32 of the Corporate Tax Law to set a reduced rate for production activities. Corporate tax is applied at 12.5% on the earnings that corporations holding an industrial registry certificate and actually engaged in production activity derive exclusively from production activities, as well as on the earnings that corporations engaged in agricultural production activity derive from those activities. This provision is in effect for the 2027 and subsequent taxation periods.

Istanbul Finance Centre Provisions (Articles 9, 12 and 13)

The law contains three separate provisions regarding the Istanbul Finance Centre. Article 9 integrates the earnings deduction directed at Istanbul Finance Centre participants into Article 32/C of the Corporate Tax Law. Article 12 aligns the rules in order to prevent qualified service centre personnel from benefiting simultaneously and in duplicate from both the Istanbul Finance Centre wage exemption and the Income Tax Law wage exemption. Article 13 extends the expiry date of the Istanbul Finance Centre incentives from 2031 to 2047, and the application period from fifteen years to twenty years.

R&D, Techno-Ventures and Incubator Entrepreneurs (Article 11)

Article 11 of the law adds two new paragraphs to the Law on the Support of Research, Development and Design Activities. Accordingly, non-publicly held companies holding a techno-venture badge issued by the Ministry of Industry and Technology may carry out conditional capital increases based on debt agreements convertible into shares, and may be exempted from the relevant restrictions of the Turkish Commercial Code in such transactions. In addition, digitally defined companies qualifying as incubator entrepreneurs are exempt from certain chamber and exchange registration fees for up to three years from their establishment.

Other Technical Provisions (Articles 1 and 3)

Alongside direct incentives, the law also contains two procedural technical provisions. Article 1 amends the deferral provision of the Law on the Procedure for the Collection of Public Receivables, raising the upper limit of the period from "36" to "72" and increasing the amount limit referred to in the text from "fifty thousand" Turkish lira to "one million" Turkish lira. This change is intended to provide taxpayers with greater flexibility in the instalment payment of public receivables. Article 3, for its part, is a technical correction aligning the amount and bracket expressions in the Income Tax Law with the newly introduced exemptions.

Entry into Force (Articles 14 and 15)

The majority of the law's provisions entered into force upon publication on 4 June 2026. However, different dates of entry into force are foreseen for certain articles. For this reason, the specific date of entry into force of each provision must be considered separately.

Pursuant to Article 15, the task of executing the provisions of the law is conferred upon the President. For time-bound opportunities, and in particular the 31 July 2027 date foreseen for the foreign asset declaration, careful monitoring of the deadline is important.