Turkey’s 100% Service Export Deduction in 2026: Article 89/13 & 10/1-ğ, Minimum Tax, YMM Certification and Calculator

Turkey allows a 100% deduction for qualifying profits from certain services supplied from Turkey to customers abroad. For individuals and sole proprietors, the relevant rule is Article 89/13 of the Income Tax Law. For Turkish companies, the parallel provision is Article 10/1-ğ of the Corporate Tax Law — sometimes written as Article 10/1-g in English-language searches.

The deduction rate increased from 80% to 100% for tax periods beginning on or after 1 January 2026 under Presidential Decision No. 11257.

But 100% does not mean that every freelancer or Turkish company invoicing a foreign customer automatically pays zero Turkish tax.

The result depends on the type of service, where the customer is established, where the service is actually used, how the profit is calculated, whether the qualifying earnings are transferred to Turkey on time, YMM certification requirements and — for companies — Turkey’s domestic minimum corporate tax.

This guide explains the rules using practical examples.

Quick Answer

Turkey’s service export regime allows qualifying businesses and professionals to deduct 100% of the profit generated from specified services supplied from Turkey to qualifying foreign customers.

The key point is that this is a profit deduction, not a blanket foreign-income exemption and not a deduction equal to 100% of turnover.

A qualifying case generally requires:

1. the actual service to fall within the statutory categories;

2. the customer to be a qualifying non-resident;

3. the service to be supplied from Turkey;

4. the economic benefit of the service to arise abroad;

5. the invoice or equivalent document to be issued to the foreign customer; and

6. the qualifying earnings to be transferred to Turkey by the applicable annual tax return deadline.

For Turkish companies, another layer must then be considered: the 10% domestic minimum corporate tax. Article 10/1-ğ is specifically listed among deductions that cannot be deducted when calculating that minimum-tax base.

That means:

100% service export deduction does not necessarily mean 0% corporate tax.

For individual taxpayers, the corporate minimum-tax regime does not apply.

2026 Service Export Deduction at a Glance

What exactly changed in 2026?

Until 2022, the deduction rate was 50%.

It increased to 80% for qualifying income and profits from 2023.

Presidential Decision No. 11257, published on 30 April 2026, increased the rate under both Article 89/13 and Article 10/1-ğ to 100%, applicable to income and profits of tax periods beginning on or after 1 January 2026.

The legal mechanism did not become a general exemption for foreign-client income.

The underlying eligibility conditions still matter.

That distinction is important because the following statement is not correct:

“My client is abroad, therefore my income is tax-free in Turkey.”

The correct question is:

“Does my activity, customer, use of the service, documentation, accounting and payment flow satisfy Article 89/13 or Article 10/1-ğ?”

Which services qualify?

The statutory categories include:

The service list matters because not every professional service supplied to a foreign customer qualifies.

The Turkish Revenue Administration has specifically stated in rulings that assistance, consulting and brokerage activities are not automatically treated as the listed qualifying services.

For example, compare these descriptions:

Software development services Potentially within the statutory category.

Software consultancy Requires much more careful analysis.

Data analysis services Potentially within the statutory category.

General business consulting Not automatically within Article 89/13.

The legal classification should reflect the actual substance of the work, not simply a convenient description added to an invoice.

The contract, scope of work, invoice and deliverables should tell the same story.

The Six-Part Eligibility Test

Before calculating the deduction, we normally test the file in this order.

A calculator should only be used after these eligibility questions are understood.

Otherwise a mathematically correct tax calculation can still produce a legally incorrect result.

What does “used abroad” actually mean?

This is one of the most important tests.

A foreign customer alone is not enough.

The Turkish Revenue Administration explains the foreign-use condition by stating, in substance, that the service supplied to the foreign customer must not relate to that customer’s activities in Turkey.

Example A — potentially qualifying

A developer in Istanbul builds backend software for a US SaaS company.

The software is incorporated into the company’s international product and used in its operations outside Turkey.

This is a relatively clean fact pattern, assuming the other conditions are satisfied.

Example B — higher risk

The same developer invoices the German parent company of a multinational group.

However, the project is specifically for the German company’s Turkish subsidiary or Turkish customer operations.

The invoice is foreign, but the economic use is in Turkey.

The foreign-use condition may therefore fail.

This is why:

Foreign invoice ≠ foreign use.

Use the Turkey Service Export Tax Calculator

Before choosing between a sole proprietorship and a Turkish limited company, calculate the potential result under both structures.

→ Turkey Service Export Tax Calculator

The calculator should estimate:

Revenue → deductible expenses → qualifying profit → Article 89/13 or 10/1-ğ deduction → YMM certification position → minimum corporate tax exposure → estimated remaining tax

The important number is not simply:

“How much is my deduction?”

The more useful question is:

“After all relevant rules, how much Turkish tax remains under my structure?”

The 100% deduction applies to profit — not turnover

This distinction is fundamental.

Assume a software developer generates:

TRY 4,000,000 service revenue

and has:

TRY 1,200,000 attributable expenses.

The qualifying profit is approximately:

TRY 4,000,000 – TRY 1,200,000 = TRY 2,800,000

Subject to the detailed tax and accounting rules, the Article 89/13 deduction is therefore based on the qualifying TRY 2.8 million profit, not simply the TRY 4 million invoiced amount.

For mixed businesses, qualifying revenue, related costs and expenses should be separately tracked.

The Revenue Administration's guidance requires income, costs and expenses relating to qualifying activities to be capable of being separately identified in the accounting records.

Example 1 — Software Developer Operating as a Sole Proprietor

Assume a Turkey-resident software developer provides qualifying development services exclusively to foreign clients.

For illustration:

This simplified example assumes:

the entire activity qualifies, all applicable conditions are satisfied, there are no other taxable income items affecting the computation and the deduction is properly documented.

Because the domestic minimum corporate tax applies to corporate taxpayers, not an individual sole proprietor, there is no corresponding 10% corporate minimum-tax layer in this example.

But zero income tax on the qualifying profit does not mean zero compliance cost or zero public charges.

Social security, VAT analysis, withholding obligations, stamp taxes where relevant, bookkeeping and certification requirements remain separate questions.

Example 2 — The Same Business Through an Existing Turkish Limited Company

Now assume a Turkish limited company generates:

TRY 5,000,000 of qualifying service export profit

and all Article 10/1-ğ conditions are met.

Under the ordinary corporate-tax calculation, the 100% deduction can reduce the corresponding taxable base to zero.

But Turkey’s domestic minimum corporate tax must also be calculated.

The Revenue Administration's 2026 minimum corporate tax guide expressly identifies Article 10/1-ğ service export earnings deduction as an item that cannot be deducted from the minimum corporate tax base.

A simplified illustration:

This is deliberately simplified. Other exemptions, deductions, additions and minimum-tax adjustments can change the actual computation.

But the principle is important:

For an established Turkish company, a 100% Article 10/1-ğ deduction may still leave minimum corporate tax payable.

Example 3 — What if the Turkish Company Is Newly Established?

This changes the analysis materially.

The domestic minimum corporate tax does not apply to entities starting business for the first time for their first three accounting periods, beginning with the period in which operations start.

For example, a company genuinely beginning operations in 2026 may generally be outside the domestic minimum corporate tax for:

2026 2027 2028

subject to the statutory conditions.

This means the tax result of a newly established company may differ substantially from that of an existing company earning exactly the same amount of service export profit.

There is an important limitation.

Companies created through transactions such as mergers, transfers, conversions or certain divisions are not automatically treated as entities starting business for the first time for this purpose.

Therefore company age has become a genuine tax-model variable in 2026.

Sole Proprietor vs Turkish Limited Company: Why the Answer Changed in 2026

Before selecting a structure, the following should be modelled together:

The correct structure should therefore be chosen using an effective-tax model, rather than comparing only headline income-tax and corporate-tax rates.

The Transfer-to-Turkey Rule

This condition deserves particular attention.

To claim the deduction, the qualifying earnings must be transferred to Turkey by the applicable annual tax return deadline.

The Revenue Administration also states that where only part of the qualifying earnings is transferred within the required period, the taxpayer cannot simply claim the deduction on the transferred portion.

The deduction can be lost for the whole qualifying amount, including the portion that was transferred. A later transfer does not retroactively restore the deduction for the earlier period.

Example

Qualifying profit:

TRY 1,000,000

Amount transferred to Turkey within the required period:

TRY 900,000

Amount left abroad:

TRY 100,000

The result is not necessarily:

“Deduct TRY 900,000 and tax TRY 100,000.”

The failure to satisfy the full transfer requirement can jeopardise the entire deduction.

This is particularly relevant for professionals and businesses receiving funds through foreign banks or payment platforms and leaving balances outside Turkey.

Payment flows should therefore be monitored during the year rather than reconstructed immediately before the annual return.

Where the payment itself is already made in Turkey, the analysis may differ; the Revenue Administration's guidance contains examples where a separate transfer is not required because the payment occurred in Turkey.

YMM Certification: The Threshold Now Matters to Freelancers Too

A separate compliance development is the YMM certification requirement.

The 49 Series General Communiqué introduced certification requirements for specified exemptions and deductions appearing in income-tax and corporate-tax returns.

Article 89/13 is expressly included within the relevant certification framework.

The base limits introduced for the 2025 period were:

TRY 500,000 for an individual exemption/deduction, and

TRY 1,000,000 in aggregate where multiple relevant exemptions/deductions are involved.

The Communiqué provides for the limits to increase in subsequent years by half of the prior year's revaluation rate, with the prescribed rounding mechanism. The 2025 revaluation rate was officially announced as 25.49%.

Applying that formula gives the 2026-period levels of approximately:

Because the Article 89/13 deduction is now 100%, these thresholds can be reached relatively quickly.

For example, a sole proprietor with more than TRY 560,000 of qualifying profit may need to consider YMM certification even though no company exists.

That is a major practical point:

YMM certification is not only a corporate issue.

Because the return relating to 2026 income will be filed later, the threshold and filing mechanics should be reconfirmed against the official guidance in force when the certification report is prepared.

What is a YMM Certification Report?

A Yeminli Mali Müşavir (YMM) is a Turkish sworn financial advisor authorised to certify specified tax matters.

For taxpayers subject to the certification requirement, the issue should not be treated as an administrative formality to be considered after the tax return has already been prepared.

The underlying file must support:

the nature of the service, foreign-customer status, foreign use, revenue and cost allocation, invoices, collection flow, transfer to Turkey and the calculation of qualifying profit.

Where a taxpayer already has an appropriate full-certification arrangement, the exact reporting mechanics should be reviewed separately.

Example 4 — Both Turkish and Foreign Clients

Assume a software company has:

TRY 3,000,000 qualifying foreign-service profit

and

TRY 1,000,000 Turkish-market profit.

The Article 10/1-ğ deduction does not simply apply to the company's entire TRY 4 million profit.

The qualifying foreign activity needs to be separately identified.

Shared costs can therefore become important.

For example:

office expenses, employee costs, cloud services, software subscriptions, depreciation and general administrative expenses may support both domestic and foreign activities.

The allocation method should be reasonable, consistent and capable of being supported by the accounting records.

A tax file that assigns virtually all common expenses to the Turkish business while leaving the foreign business with artificially high qualifying profit may be difficult to defend.

VAT Service Export Exemption Is a Different Regime

This distinction should be explicit.

The Article 89/13 / Article 10/1-ğ deduction relates to income tax or corporate tax.

Turkey’s VAT treatment of exported services is governed separately.

A transaction may potentially qualify as a VAT-exported service without necessarily qualifying for the Article 89/13 earnings deduction.

Likewise, an invoice issued without Turkish VAT does not prove that the related profit automatically qualifies for the 100% income or corporate tax deduction.

Think of the analysis as two separate questions:

Question 1: What is the VAT treatment of the service?

Question 2: Does the resulting profit qualify under Article 89/13 or Article 10/1-ğ?

They should be documented separately.

Article 89/13 Is Not the Same as Turkey’s Article 20/D Foreign-Income Exemption

This distinction has become increasingly important since the introduction of Turkey’s new foreign-income regime.

Article 89/13 generally concerns active qualifying services produced from Turkey for foreign customers.

Article 20/D addresses a different category of foreign-source income and has its own eligibility rules.

A simple conceptual distinction is:

The fact that a UK Ltd, US LLC or UAE company makes the payment does not by itself determine whether income is “foreign-source” for Turkish tax purposes.

The underlying activity and legal character of the income matter.

Employee Salary Is Also Different

Article 89/13 is primarily relevant to qualifying business or professional-service income.

It should not automatically be applied to a salary merely because:

the employer is abroad, the salary is paid into a foreign bank account, or the employee works remotely from Turkey.

Foreign-employer salary requires a separate analysis of employment-income rules, Turkish tax residence, applicable exemptions, payroll exposure and any relevant double-tax treaty.

Misclassifying salary as contractor income simply to reach Article 89/13 can create substantially larger risks than the tax saving being sought.

Documentation: What Should Be in the File?

A defensible service-export file should allow another tax professional — or a tax inspector several years later — to reproduce the position taken on the return.

At minimum, the evidence normally needs to establish the customer, the actual service, its use abroad, the revenue, the related expenses, the transfer of qualifying earnings to Turkey and the calculation of the deduction.

Useful evidence commonly includes the foreign-client agreement and scope of work, invoices or professional receipts, foreign-company details, project and delivery records, correspondence establishing where the work is used, bank and payment-platform statements, revenue-and-expense reconciliations, shared-cost allocation workings and, where required, the YMM certification file.

The goal is not merely to obtain a tax result.

The goal is to build a position that remains reconstructable and defensible later.

Common Failure Points

Frequently Asked Questions

What is Turkey’s service export deduction rate for 2026?

The deduction rate is 100% for qualifying income and profits from tax periods beginning on or after 1 January 2026. Presidential Decision No. 11257 increased the rate under both Income Tax Law Article 89/13 and Corporate Tax Law Article 10/1-ğ.

Is Turkey’s 100% service export rule a tax exemption?

Technically, it is a deduction from the tax base, not a blanket exemption that allows qualifying revenue to disappear from the accounting records. The income, costs and qualifying profit still need to be properly recorded and reported.

Does every freelancer working for foreign clients qualify?

No.

The underlying service must fall within the qualifying statutory categories and the other customer, foreign-use, invoicing, transfer and documentation conditions must also be satisfied.

Can software developers qualify under Article 89/13?

Yes, software is expressly included in the statutory service categories, provided the remaining conditions are also met.

Does general management consulting qualify?

Not automatically.

The Revenue Administration has taken the position that consulting, assistance and brokerage services are not simply treated as qualifying listed services. The actual work and documentation need to be analysed.

Is the deduction calculated on revenue or profit?

On the qualifying profit/earnings, not simply gross invoice revenue.

Costs and expenses attributable to the qualifying activity need to be taken into account.

Does the money have to be transferred to Turkey?

The qualifying earnings are subject to a transfer-to-Turkey requirement by the applicable annual return deadline, subject to the detailed rules and situations where the payment itself has already occurred in Turkey.

What happens if only 90% of the qualifying earnings are transferred to Turkey?

The deduction is not automatically preserved for the 90%.

Revenue Administration guidance states that where only part of the qualifying earnings is transferred within the required period, the deduction may be lost for the transferred portion as well.

Does a Turkish limited company using the 100% deduction pay zero corporate tax?

Not necessarily.

Article 10/1-ğ is not deductible when determining the domestic minimum corporate tax base. As a result, an established company may still have minimum corporate tax exposure even where its ordinary corporate-tax base is reduced substantially or to zero.

What is Turkey’s domestic minimum corporate tax rate?

The general domestic minimum corporate tax mechanism prevents the relevant tax calculation from falling below 10% of corporate profit before specified exemptions and deductions, subject to the detailed statutory adjustments.

Does the minimum corporate tax apply to newly established companies?

Entities starting business for the first time are generally outside the domestic minimum corporate tax for their first three accounting periods, beginning with the first operating period. Special rules apply to restructurings such as mergers and conversions.

Is YMM certification required for Article 89/13?

It can be.

Article 89/13 is included within the certification regime introduced by the 49 Series General Communiqué. Relevant thresholds and reporting requirements should therefore be checked for the tax period concerned.

Is Article 89/13 the same as Turkey’s 20-year Article 20/D exemption?

No.

Article 89/13 deals with qualifying active service-export profits. Article 20/D is a separate regime and can be relevant to specified categories of foreign-source income.

Can I use Article 89/13 if I am paid by a US LLC or UK Ltd?

Potentially, but the payer’s legal form or country does not determine eligibility by itself.

The actual service, customer relationship, use of the service, invoicing, accounting and transfer conditions must be reviewed.

Does Article 89/13 also remove Turkish VAT?

No.

VAT treatment is governed by a separate statutory regime and requires a separate analysis.

Practical Decision Framework

For someone moving to Turkey or already working from Turkey for international clients, the order of analysis should generally be:

First: classify the income correctly — employee salary, independent professional income, business income, company profit or passive foreign income.

Second: determine whether the actual service is within Article 89/13 or Article 10/1-ğ.

Third: verify foreign-customer and foreign-use conditions.

Fourth: calculate qualifying net profit rather than turnover.

Fifth: model sole proprietor versus company taxation, including minimum corporate tax where relevant.

Sixth: check the transfer-to-Turkey and YMM certification requirements before the filing deadline.

Only after those steps does the headline 100% deduction become meaningful.

Calculate Your 2026 Position

If you provide services from Turkey to foreign customers, start with our:

Turkey Service Export Tax Calculator

It is designed to help model the difference between a sole proprietorship and a Turkish company and identify issues such as:

qualifying profit, the 100% deduction, domestic minimum corporate tax and potential certification requirements.

For a case-specific review, we normally examine:

your contract, service description, invoice wording, customer jurisdiction, where the service is used, expected annual revenue and expenses, payment route and existing Turkish business structure.

Request a Service Export Tax Review

Email: info@ozmconsultancy.com

Suggested subject: Turkey 100% Service Export Deduction Review

For material cases, the objective should not be merely to claim the deduction on a tax return.

It should be to establish a documented, calculation-supported and defensible tax position before the year closes.

Legal Sources

This guide is based principally on:

Turkish Income Tax Law — Article 89/13

Turkish Corporate Tax Law — Article 10/1-ğ

Presidential Decision No. 11257, published 30 April 2026

Corporate Tax General Communiqué No. 1, as amended

49 Series General Communiqué on SMMM/YMM certification

Turkish Revenue Administration — Domestic Minimum Corporate Tax Guide

Relevant Turkish Revenue Administration private rulings and official guidance

Last reviewed: September 2026.

This guide provides general information and does not constitute a case-specific tax opinion. Eligibility depends on the actual service, contractual relationship, location of use, payment flow, accounting records and the taxpayer’s legal structure.