20 Turkey 20-Year Tax

Do You Qualify as a Qualified Service Centre?

Reviewed 24 July 2026 · By Bayraktar Attorneys
In short: You qualify as a Qualified Service Centre only if you meet four conditions together: you are a Turkish capital company (an AŞ or a Ltd.) under Foreign Direct Investment Law No. 4875; you provide qualifying services to related group entities in at least three countries; at least 80% of your revenue comes from foreign affiliates; and your activities fall within the qualifying categories of coordination, management, treasury and support functions. The conditions are cumulative — all four must be satisfied. An existing subsidiary can enter the regime for periods beginning on or after 1 January 2026.

Four conditions, satisfied all at once

The Qualified Service Centre (QSC) is a new corporate category created by Law No. 7582 under Türkiye's Foreign Direct Investment Law No. 4875. It lets a qualifying company deduct almost all of its foreign-source service income from the Turkish corporate tax base. But the regime is gated by four conditions, and the operative word is cumulative: you must satisfy every one of them together, not simply most. Miss a single test and the centre does not qualify — there is no partial pass.

ConditionWhat it requiresMet?
Legal formA Turkish capital company — a joint-stock company (anonim şirket / AŞ) or a limited company (limited şirket / Ltd.)Mandatory
Geographic spreadProvides services to related group entities located in at least three countriesMandatory
Revenue concentrationAt least 80% of revenue comes from foreign affiliatesMandatory
ActivityWork falls within the qualifying categories: coordination, management, treasury and support functionsMandatory

Read the table as a single gate rather than a menu. A company that serves affiliates in four countries but earns only 60% of its revenue from foreign affiliates does not qualify; nor does one that hits every financial threshold but is set up as a branch rather than a capital company. All four boxes must be ticked at the same time.

You must be a capital company under FDI Law No. 4875

The first condition is structural. Only a Turkish capital company can hold QSC status — that means a joint-stock company (AŞ) or a limited company (Ltd.). Partnerships, sole traders, liaison offices and simple branches fall outside the category, because the regime is deliberately built on the corporate tax base and on the discipline that a capital company brings: registered share capital, statutory books and a filed annual corporate tax return.

Because the QSC sits under the Foreign Direct Investment Law No. 4875, it is designed for internationally owned groups placing a regional function in Türkiye. There is no requirement that the centre be located in any particular city — the regime is geographically neutral, so an AŞ in Ankara or Izmir qualifies on the same terms as one in Istanbul. Location only matters when you want to lift the deduction from 95% to 100%, which we cover in 95% vs 100% and the Istanbul Financial Centre uplift.

Three countries, 80% and the qualifying categories

The remaining three conditions are the substance test — they make sure the centre is genuinely a regional hub rather than a domestic company wearing a badge.

Only income that flows from these qualifying, foreign-source services feeds the deduction. That is why mapping each revenue stream against the categories — before you rely on the regime — matters as much as the headline percentages.

Converting an existing subsidiary

One of the most useful features for established groups is that the QSC is not reserved for newly formed companies. The regime applies to financial years beginning on or after 1 January 2026, including entities established before that date. In practice that means a group already running a Turkish AŞ or Ltd. that coordinates regional operations can bring that existing subsidiary into the regime, rather than incorporating a fresh vehicle.

Conversion is a matter of aligning the company to the four conditions and to the qualifying-income and profit-transfer mechanics, not of starting again. Where an existing subsidiary already serves affiliates across several countries, the practical work is usually confirming the three-country reach, testing whether the 80% foreign-affiliate revenue threshold is met on the numbers, and checking that its functions sit inside the qualifying categories. From the first qualifying period, the benefit runs for 20 accounting periods.

Quick self-check before you rely on the regime

  • Are you an AŞ or Ltd. (a capital company), not a branch or partnership?
  • Do you serve related group entities in three or more countries?
  • Is at least 80% of your revenue from foreign affiliates?
  • Do your activities sit within coordination, management, treasury or support functions?
  • Can you transfer the profit to Türkiye within the corporate tax return's filing period each year?
Secondary legislation is still landing. The QSC is a new category, and the detailed rules on how each condition is measured — how the three-country and 80% tests are evidenced, and how qualifying income is delineated — are being fleshed out in implementing legislation. Confirm your structure against the current rules before you file on the basis of the regime.

Structuring or converting a Turkish service centre?

Whether the smarter route is a new AŞ or converting an existing subsidiary turns on the four conditions and your group's revenue map. Bayraktar Attorneys sets up and adapts Turkish capital companies to meet the Qualified Service Centre tests.

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This guide is written and maintained by the international tax and corporate team at Bayraktar Attorneys, an Istanbul-based law firm advising foreign investors, expatriates and returning professionals on Turkish tax residency, corporate structuring and citizenship. It is reviewed for the Turkey 20-Year Tax project and updated as the Ministry of Treasury and Finance issues implementing guidance.

Frequently Asked Questions

What are the conditions to be a Qualified Service Centre?
Four conditions must be met together: you are a Turkish capital company (AŞ or Ltd.) under FDI Law No. 4875; you serve related group entities in at least three countries; at least 80% of your revenue comes from foreign affiliates; and your activities fall within the qualifying categories of coordination, management, treasury and support functions.
Can a branch or partnership qualify?
No. The regime is built on the corporate tax base and requires a capital company — a joint-stock company (anonim şirket / AŞ) or a limited company (limited şirket / Ltd.). Branches, liaison offices, partnerships and sole traders fall outside the category.
Does my service centre have to be in Istanbul?
No. The regime is geographically neutral, so a qualifying company can be located anywhere in Türkiye. Location only matters if you want to lift the deduction from 95% to 100%, which requires basing the qualifying functions in the Istanbul Financial Centre or an approved zone.
Can I convert an existing subsidiary instead of forming a new company?
Yes. The regime applies to financial years beginning on or after 1 January 2026, including entities established before that date. An existing Turkish AŞ or Ltd. that meets the four conditions can enter the regime rather than incorporating a new vehicle.
How long does the benefit last once I qualify?
The Qualified Service Centre benefit applies for 20 accounting periods, provided that in each period the qualifying profit is transferred to Türkiye within the statutory filing period for the annual corporate tax return.

Sources & Legal References

  1. Law No. 7582, Official Gazette No. 33270, 4 June 2026 (Qualified Service Centre under FDI Law No. 4875)
  2. Regfollower — Türkiye Enacts Law Introducing Sweeping Corporate Tax Reforms and Incentives — regfollower.com
  3. CCS Law — Türkiye Tax Incentives 2026: New Law for Investors, Expats and Businesses — ccs.law