# Acquire a Game Company in Turkey: Unlock VAT Refunds and Marketing Incentives

# **Acquire a Game Company in Turkey: Unlock VAT Refunds and Marketing Incentives**

## Introduction: The Smart Route into Turkey’s Booming Gaming Sector

Turkey is now firmly established as one of the fastest-growing gaming hubs in the world. A **young and creative developer base**, combined with government support, makes the country uniquely attractive for global investors.

But the **real advantage** is financial: acquiring an existing Turkish game company (with at least 1 year of operational history) unlocks **immediate eligibility for VAT refunds on advertising and platform commission expenses**—cost categories that dominate gaming business models.

At the same time, ownership of such an entity allows investors to apply for **government-supported marketing incentives**, such as those listed under **EK-31A**. These programs cover international promotion, advertising, and marketing activities for games, apps, and digital platforms.

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## 1\. Advertising and Commission Costs: The Hidden Burden in Gaming

### 1.1 Advertising as Growth Fuel

Most gaming studios allocate **40–60% of their revenue** to user acquisition campaigns. Google Ads, Meta Ads, and influencer-driven campaigns represent essential but heavy expenditures.

### 1.2 Platform Commissions: The 30% Cut

Apple App Store and Google Play typically charge **30% commission** on in-app purchases. Steam and similar platforms impose comparable rates.

### 1.3 Why Refunds Transform Economics

Without refunds, these are sunk costs. With Turkish VAT mechanisms, investors can recover **up to 18–20%** of these expenses. Over time, this refund system radically improves cash flow and profitability.

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## 2\. The Legal Framework for VAT Refunds

### 2.1 Export of Services Principle

Under Turkish VAT Law, revenues derived from exports of digital services—including games and mobile applications sold abroad—are exempt. This exemption allows companies to apply for **refund of input VAT** paid on expenses linked to such exports.

### 2.2 Refundable Categories

* **Advertising costs**: Google Ads, Meta Ads, TikTok Ads.
    
* **Commission fees**: App Store, Google Play, Steam.
    
* **Marketing services**: Third-party publishers, influencers.
    
* **Operational services**: Cloud hosting, payment gateways.
    

### 2.3 The One-Year Rule

A newly incorporated entity cannot apply for VAT refunds immediately. Tax authorities typically require at least **one fiscal year** of operations.

**Acquisition Advantage**: By buying an existing company with over one year of records, investors **bypass the waiting period** and file refund claims immediately.

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## 3\. Financial Impact of Refunds

| Expense Category | Annual Spend | Refund Eligibility (Approx. 18%) | Net Recovery |
| --- | --- | --- | --- |
| Advertising (Google/Meta) | $1,000,000 | $180,000 | Immediate |
| App Store Commissions | $500,000 | $90,000 | Immediate |
| Steam Fees | $250,000 | $45,000 | Immediate |

**Total Benefit**: ~$315,000 annual refund on a $1.75M spend.

---

## 4\. Case Study: European Studio Acquisition

A European investor spending $2M annually on global marketing faced two options:

* **New Incorporation**: wait 12 months before refund eligibility, losing ~$360,000.
    
* **Acquisition of 2-year-old Turkish studio**: immediate eligibility, refunding ~$360,000 within the first year.
    

**Outcome**: Acquisition more than justified its price within the first year.

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## 5\. Marketing and Promotion Incentives: EK-31A Advantage

VAT refunds are not the only financial benefit. Turkey’s Ministry of Trade provides **direct reimbursement** for international promotion expenses.

### 5.1 Software, Gaming, App & Digital Platform Promotion

If the company develops a **game, app, or digital service platform**, expenses for **international promotion and marketing** activities are eligible. Covered costs include:

* Digital advertising campaigns abroad,
    
* Social media promotions,
    
* App Store optimization (ASO) campaigns,
    
* International fairs, expos, and conferences,
    
* Promotional videos, demo productions, and PR campaigns.
    

### 5.2 General Brand Promotion

Companies may also claim support for **general-purpose brand advertising**—corporate videos, media campaigns, or brand-building exercises—provided these fall under **EK-31A supported activities**.

* **Special promotions** (e.g., sponsorships, major international PR events) require **prior approval**.
    

### 5.3 Strategic Benefit

* Refunds reduce costs already incurred.
    
* **EK-31A support** provides *cash reimbursements* for planned marketing activities.
    
* Combined, they create a **dual financial advantage** for investors.
    

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## 6\. Due Diligence in Acquisition

When acquiring a Turkish game company, investors must ensure:

* At least **1 year of clean tax history**.
    
* No unresolved VAT refund disputes.
    
* Past eligibility for EK-31A supports documented.
    
* Intellectual property (game code, trademarks, publishing rights) secured.
    

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## 7\. Acquisition Process Step by Step

1. **Identify Target Company**
    
    * Preferably technopark-based with export history.
        
2. **Preliminary Agreements**
    
    * Non-disclosure and term sheet.
        
3. **Due Diligence**
    
    * Financial, legal, IP, and incentive eligibility review.
        
4. **Share Purchase Agreement (SPA)**
    
    * Warranties covering VAT refund rights and incentive eligibility.
        
5. **Registry and Notifications**
    
    * Shareholder changes at Trade Registry, tax office, and SGK.
        
6. **Refund and Support Applications**
    
    * Submit VAT refund claims and apply for EK-31A reimbursements.
        

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## 8\. Risk Management

* **Tax Liabilities**: Obtain clearance certificates.
    
* **Documentation Gaps**: Ensure all advertising/commission invoices are archived.
    
* **Delayed Refunds**: Build conservative cash flow models.
    
* **Employment Issues**: Verify compliance with labor and SGK requirements.
    

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## 9\. Comparative Analysis: Incorporation vs. Acquisition

| Criteria | New Incorporation | Acquisition (Existing &gt;1 Year) |
| --- | --- | --- |
| VAT Refund Eligibility | After 12+ months | Immediate |
| EK-31A Marketing Support | After eligibility setup | Immediate |
| Market Entry Speed | 9–12 months | 2–3 weeks |
| Financial Efficiency | Delayed | Immediate refund & reimbursement |
| Risk | Lower at start | Managed with due diligence |

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## 10\. Frequently Asked Questions

**Q1: Can foreigners fully own Turkish gaming companies?**  
Yes, there are no foreign ownership restrictions.

**Q2: How quickly can refunds be received after acquisition?**  
Typically within 3–6 months, depending on documentation quality.

**Q3: Are EK-31A supports automatic?**  
No. Companies must apply, but eligibility starts immediately post-acquisition.

**Q4: Do refunds apply to global advertising spend?**  
Yes, as long as the invoices are billed to the Turkish entity and linked to export revenues.

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## Conclusion: The Double Benefit Strategy

Acquiring a Turkish game company with at least one year of history provides **two immediate financial advantages**:

1. **VAT Refunds** on advertising and commission expenses—transforming sunk costs into recoverable cash.
    
2. **Government Marketing Supports (EK-31A)**—reimbursing future international promotion expenses.
    

For foreign investors, this is not simply an entry strategy into Turkey—it is a **financially optimized route** that enhances ROI from the very first year.

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## Reach Us

👉 If you are considering **acquiring a Turkish game company** to unlock VAT refunds and government marketing supports, our advisory team provides:

* Comprehensive **due diligence** on refund eligibility,
    
* Structuring of **SPA with protective clauses**,
    
* Guidance on **EK-31A applications and compliance**,
    
* End-to-end legal and tax advisory.
    

Contact us today to explore opportunities tailored to your investment strategy.

info@ozmconsultancy.com

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