The Türkiye and Italy tax treaty: what leaving profit costs
The Italian treaty is one of the simplest in Türkiye's network: a flat 15% on dividends with no shareholding threshold to satisfy, 15% on interest and 10% on royalties. There is nothing to structure for and nothing to get wrong.
Türkiye refunds half of what a software company or game studio spends on advertising, app store commissions and hosting when it sells to customers abroad, and up to 70% when those customers are in one of twenty target markets. It is paid in cash, against invoices you have already settled. Try it with your own numbers.
01Where does the Italy treaty actually save money?
Türkiye withholds 20% on a royalty with no treaty in place and 10% under this one, so on $500,000 of licence fees paid to a parent in Italy, $50,000 a year stays with the group instead of going to the tax office.
- Licence fee leaving Türkiye$500,000
- Withheld without a treaty, at 20%$100,000
- Withheld under this treaty, at 10%$50,000
- What the treaty saves on this payment$50,000
02What does it cost to pay a dividend to Italy?
This treaty caps Türkiye at 15% and Türkiye already charges 15% at home, so paying a dividend to a parent in Italy costs 15% either way.
- What Türkiye charges with no treaty15%
- The ceiling this treaty sets15%
- What Türkiye actually deducts15%
03What does Türkiye withhold on payments to Italy?
| Payment leaving Türkiye | What you actually pay | Türkiye's rate with no treaty | The ceiling this treaty sets | Conditions |
|---|---|---|---|---|
| Dividends | 15% | 15% | 15% | The treaty allows Türkiye up to 15% here, which is above the 15% it charges anyway, so this line is unchanged by the treaty.15%, with no shareholding threshold to meetsource |
| Interest | 10% | 10% | 15% | The treaty allows Türkiye up to 15% here, which is above the 10% it charges anyway, so this line is unchanged by the treaty.source |
| Royalties | treaty helps10% | 20% | 10% | Türkiye's domestic royalty rate is 20%source |
04How does the Italy treaty compare with Türkiye's others?
Italy shares its 15% dividend rate with Belgium, Canada, France, India and 5 others. 10 of the treaties here go lower, down to 5% for Austria.
- 5%6
- 10%4
- 15%10
Most of Türkiye's treaties split into a qualifying rate and a fallback, which makes the shareholding structure worth money. Italy does not. At a flat 15% it sits mid-range, better than the 20% fallback several treaties impose and worse than the 5% Germany, Austria and Switzerland allow.
05What happens to the money once it lands in Italy?
| In Italy | Rate |
|---|---|
| Corporate tax on ordinary profit | 24%source |
| Withholding tax on dividends to a foreign parent | 0% or 26%, depending on the recipientsource |
Türkiye against Italy, measure by measure.
06What catches out groups based in Italy?
- A flat rate means no planning upside. Where Germany rewards a 25% holding with 5%, Italy pays 15% regardless.
- Interest at 15% is at the top of the treaty range, so funding the Turkish company by loan from Italy is expensive relative to equity.
- Italy's own domestic treatment of outbound dividends depends on the recipient, so the return leg needs checking separately.
07How does this sit alongside what Türkiye pays Italy groups back?
For an Italian group the treaty fixes what a distribution costs at 15%, and the money moving the other way is where the decisions still are. Türkiye pays 50 to 70% of qualifying spend back in cash, on invoices, with no link to how profit is taken out.
| What you spend it on | Programme item | Paid back | Annual cap |
|---|---|---|---|
| Ads and player acquisition | Digital product promotion: ads & marketing (up to 10 products/yr) | 50% to 70% | 50 000 000 ₺ ≈ $1,043,841 |
| App store and platform commissions | App store & platform commissions (up to 10 products/yr) | 50% | 20 000 000 ₺ ≈ $417,537 |
| Hosting and servers | Hosting costs | 50% | 5 000 000 ₺ ≈ $104,384 |
What Türkiye would pay back on your spending
Türkiye runs a government programme that refunds part of what a software company or game studio spends on reaching customers abroad. It covers advertising, app store and platform commissions, and hosting. The refund is paid in cash against invoices the company has already settled, so it does not depend on the company making a profit. The standard rate is 50%, and it rises to 70% when the customers being targeted are in one of the twenty countries on the Turkish Ministry of Trade's target list.
Put your own yearly figures in below. The rates and the annual caps come from the same file as our full calculator, and the total updates as you type.
08Questions we get asked
Is there any way to get below 15%?
Not under this treaty. The rate does not vary with shareholding, which is unusual in Türkiye's network.
Does that make Italy a poor choice?
It makes it a predictable one. For a group that will not hold 25% anyway, a flat 15% beats a 20% fallback.
Who is telling you this
CyberScope Solutions is an Istanbul consultancy that manages Türkiye's IT export incentive claims for software companies and game studios. Treaty rates decide what a group pays to move profit, and they come up in almost every first conversation, so we keep them written down rather than looked up each time.
- Every figure is sourced. Each number links to the page it came from and carries the date we last checked it.
- You find out early if it is not for you. The first call is thirty minutes and we will say plainly if your spend pattern does not suit the programme.
- These pages get rebuilt, not left. Rates and caps come from the same file as our calculator, so when one changes the page changes with it.
Turn that number into money
Send us the rough shape of your spend. You get back what it is worth, what setting it up involves, and how fast the first claim can go in. Companies already operating here treat this as routine, and the six month window means the clock is running on invoices you have already paid.
- A reply from a person within one working day
- No mailing list, no drip sequence
- Thirty minutes, and you keep the numbers either way
Got it.
We will read it properly and reply within a working day. If you would rather get it over with now, pick a time that suits you.
Book a 30 minute call09Where these numbers come from
- https://taxsummaries.pwc.com/turkey/corporate/withholding-taxes checked 2026-08-21
- https://taxsummaries.pwc.com/quick-charts/corporate-income-tax-cit-rates checked 2026-08-20
- https://taxsummaries.pwc.com/quick-charts/withholding-tax-wht-rates checked 2026-08-20