Export Incentives in Turkey for Software, Apps, and Games

A Practical Compliance Guide for Advertising and Commission Support (2026)

Turkey has become an increasingly attractive jurisdiction for software companies, mobile app publishers, and game studios seeking to optimize both taxation and operational costs. Beyond the widely discussed export-of-services tax advantages, there is a second layer of financial benefit that is often underestimated: government-backed incentives covering advertising and platform commission expenses.

However, accessing these incentives is not a matter of simply having a Turkish company. The system is highly structured, and eligibility depends on whether the business is configured in a way that satisfies specific legal, technical, and operational criteria. In practice, many applications are rejected not because the business lacks substance, but because its structure does not align with the expectations of Turkish authorities.

This guide explains how the system works, what requirements must be met, and where most companies fail.

Understanding the Scope of Incentives

The incentive regime is primarily designed to support service exports, particularly in sectors such as software development, SaaS, mobile applications, and digital gaming.

Two main categories of support are relevant:

First, advertising and marketing expenses. Companies can receive partial reimbursement—typically around 50%, subject to annual caps—for digital advertising spend. This includes major global platforms such as Google Ads, Meta (Facebook and Instagram), TikTok, and various programmatic ad networks used in mobile growth strategies.

Second, platform commission expenses. Fees paid to platforms such as Apple App Store, Google Play, or other digital marketplaces may also be eligible for support under similar reimbursement ratios.

Taken together, these incentives can significantly reduce customer acquisition costs and improve profitability—if the structure is compliant.

The Core Principle: Substance Over Form

The most critical concept to understand is that Turkish authorities do not evaluate eligibility based on intention, but on economic and legal substance.

In other words, it is not enough to say that a Turkish company is “involved” in the business. The authorities will examine:

• Which entity owns the product

• Which entity controls revenue

• Which entity incurs marketing expenses

• Whether these elements are aligned

If there is a mismatch between these layers, the application is likely to fail.

Domain Ownership: The Most Overlooked Risk

One of the most common failure points is domain ownership.

For a product to qualify, the domain associated with the software, platform, or game must be registered under the Turkish company. This is verified through WHOIS records and supporting documentation.

If the domain is owned by:

• A foreign parent company

• An individual founder

• Another group entity

then the authorities may conclude that the Turkish company is not the true economic owner of the product.

This single issue is often sufficient to disqualify an otherwise eligible business.

Mobile Applications: Alignment at the Platform Level

For mobile applications, compliance extends beyond the domain into platform-level visibility.

Applications listed on platforms such as Apple App Store or Google Play must clearly reflect the Turkish company as the publisher or legal entity. Additionally, the financial flows—particularly revenues—should be linked to a Turkish bank account associated with the company.

If the app store listing shows a foreign entity while the Turkish company applies for incentives, this creates a structural inconsistency that will likely trigger rejection or further scrutiny.

Revenue and Platform Alignment

Another key dimension is where revenue is generated and recognized.

Authorities will assess:

• Which entity receives payments from platforms

• Which entity invoices customers (if applicable)

• Whether marketing expenses are incurred by the same entity that earns the revenue

If advertising spend is incurred by the Turkish company but revenue flows to a foreign entity, the system breaks from a compliance perspective. The incentive framework is designed to support export revenue generated by Turkish entities, not to subsidize marketing for foreign structures.

Mandatory Institutional Step: Association Membership

Before any application can proceed, companies must become members of the Service Exporters’ Association.

This is not merely a formality. Membership establishes the company within the official export ecosystem and is a prerequisite for accessing incentive programs.

There is an annual fee (recently around TRY 58,000), and the registration process involves submission of corporate documentation and activity declarations.

Electronic Signature Requirement: A Practical Bottleneck

All applications are submitted through digital government systems, which require a valid Turkish electronic signature.

This creates a practical challenge for foreign-owned businesses, as electronic signatures are typically issued to Turkish citizens or residents with appropriate credentials.

In such cases, companies often rely on:

• Local directors or authorized representatives

• Power of attorney structures

Failure to resolve this issue early can delay or block the entire application process.

What Authorities Expect Before Approval

Before moving forward, authorities will request a structured dataset that typically includes:

• Product and game names

• Domain addresses and ownership records

• Platform listings (App Store, Google Play, web platforms)

• Advertising platforms used

• Monthly or periodic advertising expenditure

This is not a superficial review. The data is used to verify consistency across legal ownership, operational activity, and financial flows.

Common Structural Mistakes

In practice, several recurring mistakes prevent companies from accessing incentives:

The first is assuming that having a Turkish company is sufficient. Without aligning ownership, revenue, and operations, the entity becomes merely a formal layer with no substantive role.

The second is leaving domains registered under foreign entities or individuals. This creates immediate doubt about ownership.

The third is maintaining app store listings under a foreign publisher while attempting to claim incentives in Turkey.

The fourth is failing to link advertising spend and revenue to the same entity, making it impossible to demonstrate a coherent export activity.

Each of these issues can independently lead to rejection.

A More Strategic Perspective

For international founders, accessing Turkish incentives is often not a compliance exercise alone—it is a structural decision.

In many cases, companies need to:

• Reassign intellectual property or usage rights

• Transfer domains to the Turkish entity

• Update platform listings

• Align payment and banking flows

This restructuring phase is critical. Attempting to apply without it usually results in delays or denials.

Final Insight

Turkey’s export incentive regime offers a powerful combination of:

• Reduced tax exposure on export income

• Direct reimbursement of marketing and platform costs

But the system is not designed to accommodate loosely structured international setups.

The real question is not whether a company operates in software, gaming, or SaaS. The real question is whether its legal, technical, and financial architecture is aligned with the expectations of the incentive framework.

Closing Note

For companies considering Turkey as a base for global digital operations, the opportunity is substantial—but so is the importance of getting the structure right from the outset.

A properly configured setup can unlock both tax efficiency and direct financial support. An improperly configured one can result in missed opportunities, or worse, compliance exposure.

A pre-application structural review is not optional. It is the decisive factor between approval and rejection.

Reach us info@ozmconsultancy.com