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.

Local Representative in Turkey – Contact Us

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