Setting Up a Mobile Gaming Company in Turkey for Foreigners
Setting Up a Mobile Gaming Company in Turkey for Foreigners
Setting Up a Mobile Gaming Company in Turkey for Foreigners
A Legal, Financial, and Strategic Guide (2025 Edition)
Executive Summary
Mobile gaming is now the dominant segment of the global gaming industry, and Turkey has emerged as a serious contender in this landscape. Over the past decade, Turkish mobile game developers have achieved global success, drawing attention from international investors and strategic buyers. What is less known, however, is how accessible Turkey has made its mobile gaming ecosystem for foreign entrepreneurs through a combination of generous government incentives, favorable tax rules, and an increasingly business-friendly regulatory environment.
This guide is designed for foreign founders, investors, and mobile game studios seeking to establish a presence in Turkey, with a particular emphasis on entity setup, legal compliance, VAT and tax issues, IP management, and government-backed incentive programs.
1. Why Turkey for Mobile Game Development?
1.1 Explosive Local Ecosystem
Turkey has produced several global mobile game hits, including Peak Games, Dream Games, and Ruby Games, which have secured significant investment and acquisition deals from global tech giants. The country continues to rank high in global app downloads and user engagement metrics.
1.2 Export-Oriented Incentive Model
The Turkish government views mobile games as digital exports and offers sizable non-refundable cash incentives to companies with a global audience. Foreign-owned companies registered in Turkey can fully benefit from these incentives.
1.3 Cost-Effective & Talented Workforce
Compared to Western Europe and North America, Turkey offers access to highly skilled developers, artists, and engineers at a fraction of the cost — with most concentrated in Istanbul, Ankara, Izmir, and Eskişehir.
2. Legal Basis for Foreign-Owned Mobile Game Companies
2.1 100% Foreign Ownership Permitted
Under Law No. 4875, foreign individuals and entities may hold 100% of the shares in a Turkish company. There is no restriction on sector, and mobile gaming is treated as a sub-sector of the software and IT industry.
2.2 Common Entity Type: Limited Liability Company (LLC)
A Limited Liability Company (Limited Şirket) is the most efficient vehicle for foreign founders. It allows full ownership, low incorporation capital, and qualifies for incentives.
| Entity Type | Min. Shareholder(s) | Min. Capital | Ideal For |
| LLC | 1 (can be foreigner) | TRY 10,000 | Indie developers, start-ups |
| JSC (A.Ş.) | 1 | TRY 250,000 | Investment-seeking companies |
3. Incorporation: Step-by-Step
3.1 Documentation Required
Valid passports and addresses of foreign shareholders
Apostilled and notarized documents (translated into Turkish)
Turkish tax ID number for each foreign shareholder
3.2 Registration Flow
| Step | Timeframe | Responsible Body |
| Name reservation & drafting | 1 day | Trade Registry Office |
| Articles of association | 1–2 days | Notary Public |
| Company registration | 3–5 days | Chamber of Commerce |
| Tax registration & e-signature | 1–2 days | Tax Office + TÜBİTAK |
| Bank account opening | 3–5 days | Turkish commercial banks |
4. Regulatory Requirements for Mobile Game Companies
4.1 Choosing the Right NACE Code
To be eligible for gaming-related incentives, your company should use one of the following activity codes:
62.01.01 – Custom software development (mobile, web)
58.21.01 – Publishing of mobile/computer games
These must be declared during the setup process and are crucial for incentive eligibility.
4.2 Content Regulation Compliance
Turkey does not require a license for publishing mobile games. However, the following laws apply:
Law No. 5651 on Internet Broadcasts (for online games)
KVKK (Turkish GDPR) – All apps must comply with Turkey’s Personal Data Protection Law
Age Ratings – Optional but recommended (e.g., IARC, PEGI)
5. Mobile Gaming Incentives in Turkey (2025)
5.1 Advertising & User Acquisition Support
Turkey’s Ministry of Trade reimburses up to:
TRY 15 million per game/year for global digital marketing (e.g., Meta, Google, TikTok)
Up to 3 mobile games per company are eligible
Extra TRY 15 million top-up support is available for selected companies
5.2 App Store Commission Refund
Developers can get reimbursed for commissions deducted by platforms like:
Apple App Store
Google Play
Unity Ads, Applovin, Ironsource, Vungle
Max refund: TRY 3.7 million per game, up to 3 games per year.
5.3 Personnel & Tooling Support
| Category | Max Amount | Description |
| Engineer Salary Support | TRY 210,000/employee | 50% of net monthly salary for Turkish developers |
| Tool/Analytics/Database Aid | TRY 1.8 million/company | SDKs, analytics platforms (e.g., Firebase, GameAnalytics) |
6. Taxation of Mobile Game Companies in Turkey
6.1 Corporate Taxes
| Tax Type | Rate (2025) | Notes |
| Corporate Income Tax | 25% | Profits of Turkish company |
| VAT | 20% | Exported mobile games are VAT-exempt |
| Dividend Withholding | 10-15% | Based on DTTs with shareholder country |
6.2 VAT Zero-Rating on Mobile Games
If the mobile game is:
Developed in Turkey
Downloaded and used outside of Turkey
Paid for by foreign users (via stores)
Then the sale is considered an export, and VAT is not applied.
7. Employment of Developers and Artists
7.1 Hiring Foreign Talent
Work permits required for non-Turkish nationals
Company must employ 5 Turkish nationals per 1 foreign employee
Applications are made via Ministry of Labor
7.2 Social Security & Payroll
All employees must be registered with SGK.
| Payroll Obligation | Percentage |
| Employer Social Security | ~20.5% |
| Employee Withholding Tax | 15–40% |
| Stamp Tax | 0.759% |
8. Protecting Your Game IP in Turkey
8.1 Trademark Registration
Company name, logos, and game titles can be registered with TÜRKPATENT.
Duration: ~6 months.
8.2 Code and Design Protection
Your mobile game’s source code is protected under Copyright Law (No. 5846).
Optional: Deposit source code with a notary for evidentiary strength.
8.3 International Protection
Consider using the Madrid Protocol for trademark protection in multiple jurisdictions via one filing.
9. Risks and Common Pitfalls
| Issue | Risk Level | Mitigation Strategy |
| Delayed incentive payments | Medium | Work with experienced consultancy |
| FX volatility | High | Invoice in EUR/USD, consider forward contracts |
| App store refunds disputes | Low | Maintain audit trail and ad performance logs |
| Ineligible NACE code | High | Legal review before registration |
10. Comparing Turkey with Other Jurisdictions
| Criteria | Turkey | Poland | UAE (ADGM) |
| Ownership Limit | 100% foreign-owned | 100% foreign-owned | 100% foreign-owned |
| Corporate Tax | 25% (can be reduced) | 19% | 9% |
| Incentives | YES (Cash + R&D) | YES (EU Funds) | Limited |
| Labor Costs | Low | Medium | High |
| Time to Incorporate | 5–7 days | 7–10 days | 10–15 days |
Conclusion
Establishing a mobile gaming company in Turkey offers foreign founders an exceptional combination of high-margin potential, substantial government incentives, and direct access to a dynamic developer ecosystem. While setup and compliance require attention to legal and tax nuances, the ROI can be significant if structured properly.
Call to Action
Are you planning to scale your mobile gaming operations into a new jurisdiction?
Let our team help you unlock Turkey’s full potential.
📧 Contact us at info@ozmconsultancy.com to schedule a consultation on incorporation, grant eligibility, and IP protection strategies tailored for mobile game developers.
