95% vs 100%: The Istanbul Financial Centre Uplift
The base deduction: 95% of qualifying foreign-source service income
The engine of the Qualified Service Centre (QSC) is a deduction, not a headline rate cut. A qualifying centre removes 95% of its qualifying foreign-source service income from the corporate tax base, so tax bites on only the remaining sliver. Crucially, this base benefit is geographically neutral: it is the same whether the company sits in Istanbul, Ankara, Izmir or anywhere else in Türkiye. Location is not part of the price of admission to the 95%.
What changes with location is only the top five points. Basing the qualifying functions in the Istanbul Financial Centre (IFC) or another approved zone lifts the deduction the rest of the way, to a full 100%. Think of 95% as the national floor and the extra five points as an IFC/approved-zone uplift you can choose to unlock.
| Where the qualifying functions sit | Deduction from the corporate tax base | Effect |
|---|---|---|
| Anywhere in Türkiye (general rule) | 95% of qualifying foreign-source service income | Geographically neutral base benefit |
| Istanbul Financial Centre or an approved zone | 100% of qualifying foreign-source service income | Base plus the five-point uplift |
The Istanbul Financial Centre uplift to 100%
The difference between 95% and 100% sounds small, but it is the difference between a small residual corporate tax charge and none at all on the qualifying income. For a centre with substantial foreign-source service income, closing that last five-point gap can be worth pursuing — and the way to do it is location. Inside the IFC, the QSC deduction reaches 100%, so the whole of the qualifying foreign-source service income comes out of the tax base.
The IFC is not an arbitrary choice of address. It is Türkiye's dedicated financial hub, and Law No. 7582 pairs the QSC uplift with a wider IFC package — including a 100% corporate tax exemption on financial-services export income that now runs all the way to 2047. We set out that broader regime in the Istanbul Financial Centre incentives extended to 2047. For a group deciding where in Türkiye to place a regional coordination or treasury function, the IFC therefore offers both the five-point QSC uplift and a longer-dated financial-services exemption in the same location.
The 20-period horizon
The deduction — whether 95% or 100% — is not a one-off. It applies for 20 accounting periods. That long horizon is what makes the regime a genuine location decision rather than a short-term tax play: a group placing a regional hub in Türkiye is looking at two decades of sheltered qualifying income, which is enough to justify building real substance and headcount around the centre.
The 20-period clock and the personnel incentives make the QSC a structural commitment. Groups typically weigh it alongside the centre's other cost drivers — including the income-tax break for qualified staff covered in the QSC personnel tax break — rather than as a standalone number.
The repatriation condition you cannot skip
The deduction is conditional, and this is the condition that most often trips up the unwary. In every period, the qualifying profits must be transferred to Türkiye within the statutory filing period for the annual corporate tax return. The benefit is designed to bring real money into the Turkish economy, so the profit cannot simply be parked offshore while the deduction is claimed — it has to arrive in Türkiye within the filing window each year.
95% vs 100% — the essentials
- 95% is the general deduction, available anywhere in Türkiye (geographically neutral).
- 100% applies inside the Istanbul Financial Centre or an approved zone — the five-point uplift.
- The benefit runs for 20 accounting periods.
- Each period, qualifying profit must be transferred to Türkiye within the corporate tax return's filing period.
- The deduction attaches only to qualifying foreign-source service income.
95% or 100% — where should your centre sit?
The five-point uplift, the 20-period horizon and the annual repatriation deadline all have to work together. Bayraktar Attorneys models the difference for your group and structures the centre in the right location.
Discuss your service centre →Frequently Asked Questions
What is the difference between the 95% and 100% QSC deduction?
Do I have to be in Istanbul to use the regime?
How long does the QSC deduction last?
What is the profit-repatriation condition?
Does the deduction apply to all of the company's income?
Sources & Legal References
- Law No. 7582, Official Gazette No. 33270, 4 June 2026 (Qualified Service Centre under FDI Law No. 4875)
- Regfollower — Türkiye Enacts Law Introducing Sweeping Corporate Tax Reforms and Incentives — regfollower.com
- CCS Law — Türkiye Tax Incentives 2026: New Law for Investors, Expats and Businesses — ccs.law