Steam Must Appoint a Local Representative in Turkey
Originally published by Evren Özmen, CPA
Local Representative Services Provided by Our Firm
Steam, as a digital game platform with millions of active users in Turkey, is required to appoint a local representative in Turkey under the upcoming regulatory framework targeting foreign digital game distributors.
Turkey is extending the local representative obligation model—previously imposed on global social media platforms—to digital game stores and distribution platforms. Under this framework, foreign-based gaming platforms serving Turkish users must designate an authorized local representative in Turkey to ensure regulatory compliance and uninterrupted access to the Turkish market.
For Steam, appointing a local representative is not optional. It is a mandatory compliance step to avoid sanctions and operational disruption in Turkey.
Why Steam Must Appoint a Local Representative in Turkey
Based on the draft regulations and the enforcement approach adopted by Turkish authorities:
Digital game platforms with high user traffic from Turkey fall within regulatory scope
Authorities require a locally reachable and legally accountable representative
Platforms without a local representative may face administrative fines and bandwidth throttling
Sanctions can be lifted once a compliant representative is appointed
Accordingly, game platforms must ensure that a properly structured local representative is in place to maintain service continuity in Turkey.
Scope of a Local Representative
A local representative in Turkey:
Is not a distributor or reseller
Does not collect revenue or issue invoices
Does not sign contracts or make commercial decisions
The role is strictly limited to regulatory and compliance functions, including:
Acting as the official point of contact with Turkish authorities
Managing correspondence with the Information and Communication Technologies Authority (BTK)
Coordinating compliance requests related to content, age ratings, and platform obligations
Managing enforcement risks such as access blocking or bandwidth restriction
⚠️ An improperly structured local representative may create permanent establishment and corporate tax exposure in Turkey.
Local Representative Services – Our Firm’s Offering
Our firm provides local representative services in Turkey specifically designed for foreign digital game platforms and global gaming companies.
Our Services Include:
Acting as Steam’s official local representative in Turkey
Managing all regulatory correspondence with BTK and other authorities
Continuous monitoring of gaming-related regulatory obligations
Coordination of content, age-rating, and platform compliance requirements
Crisis management in case of administrative sanctions or access restrictions
Structuring the local representative model to avoid permanent establishment and tax risk
Our services are strictly limited to regulatory representation and are fully separated from any commercial or revenue-generating activities.
Why Proper Structuring Is Critical for Steam
For global platforms like Steam, appointing a local representative without careful structuring may lead to:
Corporate income tax exposure
VAT and withholding tax risks
Employment and payroll obligations
Expanded regulatory liability
A compliance-only, tax-safe representative model is therefore essential.
We ensure that the representative’s mandate is clearly defined, legally documented, and aligned with international tax principles.
If Steam—or a platform with a similar operational model—serves users in Turkey, a local representative appointment is mandatory under the evolving regulatory framework.
We provide end-to-end local representative services in Turkey, covering:
Regulatory compliance
Authority liaison
Tax-safe structuring
Ongoing risk management
Contact us to discuss local representative services in Turkey and implement a compliant, low-risk model before enforcement escalates.
info@ozmconsultancy.com
