Can you stack Türkiye's incentives, or do you have to choose?

Founders who read about Türkiye for a week end up with a list: cash back on marketing under Decision 10962, 0% corporate tax on export income, a teknopark exemption, R&D centre status. The obvious question is whether you can hold all of them at once.

Some of them combine and some of them exclude each other, and the dividing line is not where most people guess. It runs between systems rather than between programmes.

Two systems, not one list

Decision 10962 pays cash. You spend money on something the Decision names, you file, and the Ministry of Trade reimburses a percentage of it. The money arrives in your bank account.

The tax reliefs do something different. They reduce the tax on profit you have already made. The 0% export deduction under Article 10/1-(ğ) of the Corporate Tax Law, the teknopark exemption under Provisional Article 2 of Law 4691, and the reliefs under Law 5746 for R&D and design all work by shrinking a tax base.

Nothing stops a company from holding a position in both systems. A studio inside a teknopark can be reimbursed for its user acquisition spending, because reimbursing an advertising invoice and exempting software income are unrelated operations. This is the ordinary arrangement, not a loophole.

The restrictions live inside each system.

Inside the tax system, you choose

Article 4 of Law 5746 is short and it settles the question. Those who benefit from the reductions, exemptions, support and incentives under that Law cannot also benefit from Article 89(13) of the Income Tax Law, Article 10/1-(ğ) of the Corporate Tax Law, or Provisional Article 2 of Law 4691.

Read down that list. It names the export earnings deduction and the teknopark exemption explicitly. A company operating under 5746 is choosing 5746 over both of the others for the earnings concerned.

The words "for the same earnings" matter here. Where a company runs genuinely separate activities, with separate personnel and revenue tracked separately in the accounts, each activity can sit under the regime that fits it. A company with an R&D centre working on one thing and an export services business doing another is not automatically forced into one box. What it cannot do is run one team, produce one revenue line, and describe it two ways depending on which relief is being claimed.

That separation has to be real, and it has to be legible to someone reading the books later.

Inside the cash system, each expense counts once

Decision 10962 contains two programmes, the standard one and the Branding Programme, and it is explicit that the same expense is supported under one of them only.

This catches companies that qualify for both and assume the more generous cap applies automatically. It does not. An advertising invoice goes into one programme or the other, and the choice is made when you file.

The employment cost rule is the sharp edge

This is the provision that surprises people who are already using Turkish incentives, and it is worth reading closely.

The Decision does not support the employment costs of a person who, in the same period, has had support applied for under other legislation that reduces employment cost. That includes insurance premium supports, wage supports and employment-related tax reductions granted under other rules.

Two things are carved out and remain compatible: the premium discount under Article 81(1)(ı) of Social Insurance Law No. 5510, and the minimum wage support.

The practical effect is specific. Decision 10962 supports sales, marketing and business development staff, up to five people under the standard programme and up to ten under the Branding Programme. If those individuals are also drawing R&D or teknopark employment incentives for the same months, their salaries are not claimable here. The company keeps whichever relief it was already using, and the employment support line in the cash programme closes for those people.

So the sensible way to plan it is by person and by period, not by company. Engineers sitting under a personnel relief stay there. Commercial hires who are not covered by anything else are the ones the cash programme is actually aimed at.

Which combination is worth more

There is no general answer, because the two systems reach different money.

A company whose cost base is mostly engineering salaries gets more from the personnel reliefs, since that is what they are built to reduce. A company whose cost base is mostly user acquisition, app store commissions, publisher commissions and event spending gets more from the cash programme, because none of those are salaries and no personnel relief touches them.

Most studios are the second kind for a period and then become a mixture. The calculator is built around the cash side, and running your real numbers through it is a faster way to find out than reasoning about it.

Double claiming is a sanctions matter

One more thing about the boundary, since it changes the consequences.

Applying under Decision 10962 for an expense that has already been supported under other legislation is grouped in the Decision with submitting false or misleading documents and with acting contrary to an undertaking. It sits under the Article 47 sanctions rather than being treated as an ordinary eligibility failure.

That distinction matters because the two failures cost different amounts. A rejected claim costs you the claim. A claim recovered under Article 47 becomes a public receivable, and what happens to the money if the business later fails covers where that goes.

The general principle underneath all of this is easy to hold in mind. One expense, one support. One stream of earnings, one tax regime. Across the two systems, both at once.