# Turkey’s Law No. 7566 (Dec 2025): What Foreign Companies Must Know for 2025–2026 Tax, Transaction, and Payroll Planning

# Turkey’s Law No. 7566 (Dec 2025): What Foreign Companies Must Know for 2025–2026 Tax, Transaction, and Payroll Planning

## A practical compliance and deal-risk guide for international investors, CFOs, and founders

Turkey enacted **Law No. 7566** after adoption by Parliament on **4 December 2025**, and publication in the Official Gazette on **19 December 2025**. The law amends multiple tax and social security rules and has immediate implications for:

* **M&A / due diligence** (real estate and transaction taxes, penalty exposure)
    
* **Operating cost models** (payroll/social security, incentives)
    
* **Treasury and cash planning** (provisional tax timing)
    
* **Regulated sectors** (new annual license fees)
    
* **Capital markets structuring** (investment fund withholding rules)
    

If you run—or plan to run—operations in Turkey, you should treat this law as a **budget and compliance recalibration** rather than a “local tax update.”

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## Who this guide is for (and how to use it)

This article is built for:

* Foreign parent companies with a Turkish subsidiary/branch
    
* Founders and CFOs building 2026 budgets
    
* Buyers assessing Turkish targets (especially with property, payroll, or regulated activities)
    
* Investors or funds evaluating Turkish exposure
    

**How to use it:** each section provides (i) what changed, (ii) effective date, (iii) why it matters for foreign companies, and (iv) practical actions.

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# 1) Residential Rental Income: Interest Deduction Removed (Effective for 2025 Income)

### What changed

Interest on loans used for **residential** rental properties can **no longer be deducted** from taxable rental income. Interest deductibility remains available only for **non-residential** (e.g., commercial) rentals.

The **5% acquisition cost deduction** for *one* residential property (available for five years from acquisition) continues unchanged.

### Effective date

The rule applies to **income from 1 January 2025 onward**, although it entered into force on **19 December 2025**.

### Why this matters for foreign companies

If your group:

* leases housing for executives through structures involving owned property, or
    
* invests in Turkish residential real estate via corporate vehicles,
    

this change increases the effective tax friction on leverage-driven residential investments.

### Action checklist

* Re-run residential rental models assuming **no interest deduction**
    
* Reassess “leveraged residential” as a corporate treasury allocation
    
* Ensure your Turkish accounting/tax workflow reflects the retroactive application for 2025 income
    

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# 2) Provisional Corporate/Income Tax: The 4th Quarter Return Is Back

### What changed

The **4th provisional tax period** has been reintroduced. Taxpayers will again compute income on a **3, 6, 9, and 12-month basis**, including the last quarter (Oct–Dec) filing.

### Effective date

Applies to **periods starting 1 January 2025** (entered into force **19 December 2025**). Calendar-year corporations will file for **Q4 2025**.

### Why this matters for foreign companies

This is a **cash-flow timing** and **close process** issue:

* It pulls tax payments forward.
    
* It affects year-end reporting readiness, especially where HQ requires consolidated reporting.
    
* It can increase compliance load for fast-growing companies.
    

### Action checklist

* Adjust your **2026 tax calendar** and internal close schedule
    
* Confirm whether your ERP and finance team can support the **extra filing cycle**
    
* Update investor reporting timelines if you rely on Turkish entity numbers
    

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# 3) Investment Funds: Withholding Exemption Narrowed (Capital Markets Structuring)

### What changed

The law narrows the withholding exemption on gains from fund participation units held for more than one year.

Broadly, funds that are **public-facing and traded through the more transparent ecosystem** remain within the policy preference, while certain funds designed for qualified investors—especially those outside TEFAS and without portfolio constraints—are pushed out of the exemption.

### Effective date

**19 December 2025**

### Why this matters for foreign companies

If your group treasury allocates to Turkish financial instruments, or if you structure investment flows through Turkey:

* post-tax return assumptions may change
    
* withholding classification becomes a due diligence point
    

### Action checklist

* Map fund holdings by: investor type, platform (TEFAS vs not), portfolio constraints
    
* Recalculate expected net returns for 2026 onward
    
* Align corporate treasury policy with local withholding impacts
    

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# 4) Real Estate Transfers: Under-Declaration Now Triggers a “1x” Tax Loss Penalty

### What changed

If the declared transfer value is found to be understated, the associated fee can be assessed, and the **tax loss penalty** is now applied at **one full multiple (1x)** instead of 25%.

### Effective date

**19 December 2025**

### Why this matters for foreign companies (M&A and asset deals)

This is a direct **transaction risk** item:

* A buyer inheriting historical practices can face assessments post-deal.
    
* It increases the risk of “informal” valuation behaviors that were previously tolerated.
    

### Action checklist

* In due diligence, test for historic practices of under-declaration
    
* Require clear documentation supporting transfer values and valuations
    
* Consider **reps/warranties + indemnities** specifically covering fees/penalties
    

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# 5) Vehicle Transfers: 0.2% Notary Fee (Minimum TRY 1,000) From 1 January 2026

### What changed

Vehicle sales/transfers will attract a **0.2% (2 per mille) notary fee**, minimum **TRY 1,000**, calculated on the transfer price.

Exception: transfers to licensed second-hand dealers are carved out.

Additionally, the blanket exemption on fees for notary-led second-hand transfers is removed.

### Effective date

**1 January 2026**

### Why this matters for foreign companies

If you operate fleets or have employee-car programs, this is a real cost item in:

* fleet rotation
    
* corporate disposals
    
* asset transfer planning
    

### Action checklist

* Adjust fleet cost models for 2026
    
* Review whether dealer transfers are available and compliant for your structure
    

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# 6) Property Fee Base Clarified: “Declared Value Not Below the Property Tax Value”

### What changed

The legal phrasing is aligned to confirm that transfer fees are calculated on the **declared value**, provided it is **not less than the property tax value**.

### Effective date

**19 December 2025**

### Why this matters

This is mainly legal hygiene—but it reduces argument space and increases enforcement predictability.

### Action checklist

* Ensure transaction templates and internal guidance align with the clarified base
    

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# 7) New Annual License Fees: Regulated Sectors Face Recurring Fiscal Charges (From 2026)

### What changed

Multiple authorizations now attract **annual fees**, including:

* jewelry trade
    
* second-hand motor vehicle trade
    
* real estate trade authorization
    
* private healthcare and dental institutions
    
* veterinary institutions
    
* precious metals licenses
    
* aviation operating licenses
    
* certain tourism and lab/hospital permits (as listed)
    

### Effective date

**1 January 2026**

### Why this matters for foreign companies

This is not symbolic. For regulated sectors, it changes:

* operating cost baseline
    
* break-even analysis
    
* expansion planning (branch vs centralization decisions)
    

### Action checklist

* Identify whether your planned Turkey activities fall into annual-fee categories
    
* Build annual license fees into 2026 budgets
    
* Validate whether metropolitan multipliers apply based on location
    

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# 8) Property Tax: A Cap on 2026 Value Increases (Plus a 2027–2029 Framework)

### What changed

For **2026**, property tax values cannot exceed **two times** the 2025 value.

For **2027–2029**, values will increase based on the **revaluation rate**.

### Effective date

**19 December 2025**

### Why this matters

Property tax values influence other fiscal items and can affect:

* facility cost forecasts
    
* long-term lease economics (where taxes are passed through)
    
* asset valuation expectations
    

### Action checklist

* Update property tax forecasts for 2026–2029 in your long-range plan
    
* Check tax pass-through clauses in commercial leases
    

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# 9) UEFA Events: VAT Exemption on Supplies + Income/Corporate Tax Exemption for Non-Residents

### What changed

For designated UEFA events (2026, 2027 finals; 2032 tournament), certain supplies and services are **VAT-exempt**, and non-resident UEFA/teams/appointed entities may be exempt from **income/corporate taxes** on Turkey-sourced event income.

### Effective date

**19 December 2025**

### Why this matters

If you are a sponsor, vendor, broadcaster, or service provider tied to these events, the VAT and tax treatment can materially change pricing and contract structures.

### Action checklist

* Review contracts for VAT clauses and invoicing requirements
    
* Confirm eligibility criteria: residency, Turkish permanent establishment, and role classification
    

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# 10) Associations and Foundations: “No Economic Enterprise” Period Extended to 2035

### What changed

Certain income streams (already taxed via withholding) earned by associations/foundations and certain education-related units will not create an “economic enterprise” until **31 December 2035**.

### Effective date

**19 December 2025**

### Why this matters for foreign groups

Relevant mainly if your group operates:

* foundations, CSR vehicles, or education partnerships in Turkey
    

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# 11) Checks: Early Presentation Ban Extended to End-2028

### What changed

Presenting a check before the written issue date remains legally invalid until **31 December 2028**.

### Effective date

**19 December 2025**

### Why this matters

It impacts payment practices in local trade and should be understood in credit risk and payment workflows.

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# 12) Social Security (SGK) Changes: Higher Employer Cost, Reduced Incentives, Higher Ceilings

This package is where **operating cost** meets **human resources reality**.

### Key changes

* Employer share for MYO insurance rises from **11% to 12%**
    
* Non-manufacturing employers’ 4-point Treasury incentive drops to **2 points**
    
* Premium ceiling rises from **7.5x to 9x** minimum wage
    
* Buy-back premiums (excluding birth-related) and Bağ-Kur revival rate rises to **45%**
    
* Certain MYO rates rise **20% → 21%**
    
* Pension/income deductions for premium debt collection up to **25%**
    
* Presidential authority to adjust BES state contribution up to **50%** (or down to zero)
    
* Young entrepreneur one-year premium support is abolished (per the circular)
    

### Effective date

Most items: **January 2026**

### Why this matters for foreign companies

This directly affects:

* payroll cost and hiring budgets
    
* expat/local executive compensation design (due to the higher ceiling)
    
* HR policies and employee communications
    

### Action checklist

* Reprice 2026 headcount plans with updated employer SGK burden
    
* Review executive comp structures against the new premium ceiling
    
* Confirm which incentives still apply to your sector/location
    

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# What to do next (for foreign companies): A practical “first 30 days” plan

If you are a foreign company with Turkey exposure, you should treat Law No. 7566 as a trigger for a structured review:

1. **Tax compliance calendar refresh** (especially provisional tax Q4)
    
2. **Deal-risk mapping** (real estate values and penalty exposure)
    
3. **Payroll and incentives recalculation** (SGK cost baseline)
    
4. **Regulatory fee audit** (annual license fees in regulated sectors)
    
5. **Treasury and investment review** (fund withholding treatment)
    

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## Want a tailored “Law 7566 Impact Memo” for your Turkey entity?

Reach us info@ozmconsultancy.com

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