Claiming when your team is spread across several countries

A studio with a Turkish company, two founders in Istanbul, engineers in Poland and Argentina, and a marketing contractor in Berlin is a normal shape for a games company now. The question that follows is whether an arrangement like that still qualifies for anything.

Most of it does. The parts that need care are narrower than founders expect, and they sit in the tax regime rather than in the cash programme.

The claimant is the company

Decision 10962 pays a Turkish company against spending that Turkish company has made. The support attaches to the entity and its invoices.

That framing settles the majority of the question immediately. Advertising and promotion abroad, app store and platform commissions, agent and distributor commissions, hosting, trade fair participation, certification and market research are all claimed on what the company spent. None of them contains a condition about where your engineers live.

A studio running paid user acquisition from a laptop in Warsaw, billed to the Turkish company on a company card, is claiming on the same basis as a studio doing it from an office in Levent.

The two employment items, and the gap between them

Where people sit does matter for one family of items, and the Decision handles it by having two of them.

Article 19 supports sales and marketing staff in Türkiye at 50%, for up to five people, with a ceiling of 90,000 TL per person per month, about $1,890.

The same article supports staff in your overseas offices at 50%, for up to five people, with a ceiling of 250,000 TL per person per month, roughly $5,240.

Under the Branding Programme, Article 68 widens the domestic item to sales, marketing and business development staff for up to ten people.

Two points are worth taking from that.

The programme anticipates that companies claiming here have people abroad. This is not a scheme that assumes everyone sits in one building in Istanbul.

The overseas ceiling is nearly three times the domestic one, which reflects what those roles cost in the markets concerned. It also means the overseas item is doing real work for a company with a genuine presence in a target market.

The words "overseas offices" carry weight. The item supports staff in a unit abroad. A developer working from home in another country is not the same thing, and treating the two as interchangeable is the kind of assumption that turns into an Article 47 problem later.

Where a distributed team actually creates risk

The exposure is on the tax side.

The 0% deduction under Article 10/1-(ğ) of the Corporate Tax Law is not a general reward for exporting. It applies to services provided from Türkiye, by a company resident in Türkiye, to a customer abroad, where the benefit is taken abroad, with the earnings transferred to Türkiye by the tax return filing deadline.

Read the first condition against a company whose engineering, product and marketing all happen elsewhere and whose Turkish presence is a registered address and a director. The cash programme may still work for that company. The deduction asks a question it may struggle to answer.

This is not a reason to bring everyone to Istanbul. It is a reason to know which of the two systems you are relying on, and to have a defensible account of what is actually done in Türkiye. Does a Turkish company need real people in it goes through what that account looks like.

Contractors are a different category

Paying someone abroad on a contract rather than a payroll takes them out of the employment items entirely. They are not staff in Türkiye and they are not staff in an overseas office.

That does not make the cost worthless. It makes it a service cost, and whether any of it is claimable depends on what the service was. A contractor running your paid acquisition is producing advertising spend that may be claimable in its own right. A contractor writing code is producing a development cost, which is not one of the supported categories.

Classify the spend by what it bought, not by who was paid.

A practical shape that works

The arrangement most distributed studios end up with looks like this. The Turkish company holds the products, the platform accounts and the customer contracts, and does its spending from its own account. Whatever genuine decision-making and operations can sit in Türkiye do sit there. Commercial hires in Türkiye go through the domestic employment item. A real unit in a target market, if there is one, goes through the overseas item.

Engineers stay where they are, and their salaries are simply not part of the claim, which is fine because engineering salaries were never a supported category in the first place.

If you are working out whether to move people at all, do you have to live in Türkiye to own a company there covers the founder's position, and work permits for the team you bring covers what happens when you decide to relocate someone.