Does a Turkish company need real people in it?

Founders ask this one nervously, expecting to find a catch. The rules ask for less than the worry suggests, and they push in a direction that suits you.

Türkiye's IT export incentives pay a company back 50% of what it spends growing abroad, rising to 70% for activity aimed at the Ministry's target countries, and charge 0% corporate tax on income earned from exporting software and services. Both of those attach to a Turkish company, so the question of what that company has to be is a fair one to put directly.

What the rules actually say

Decision No. 10962 defines who can claim in Article 3. A beneficiary is a company resident in Türkiye and established under the Turkish Commercial Code. Article 4 then defines a service export as a service supplied by someone resident in Türkiye to a person or organisation resident abroad.

Those two sentences carry the whole substance question. The entity has to be Turkish, and the sales have to go out from it to customers abroad. Nothing in the Decision or the implementing circular sets a minimum number of employees, a minimum office size or a residency test for the owners.

Turkish corporate tax law arrives at residence from a similar direction: a company is taxed in Türkiye on its worldwide income if either its legal seat or its business centre is in Türkiye. Registering the company puts the legal seat here, which is what makes it a Turkish taxpayer and therefore eligible.

Where the requirement bites

The rules do not count heads. What they do is ask for evidence, and the evidence is much easier to produce when work is happening in the company.

Every claim is built on three things: an invoice addressed to the Turkish company, proof that the Turkish company paid it from its own account, and something showing the product is sold to customers abroad. Article 119 of the circular is firm about the middle one. Payments have to move through banking channels from the company itself or a company organically linked to it, and payments made on a shareholder's or an employee's personal card or personal account are not accepted at all. Endorsed cheques are out too.

A trading company satisfies this without thinking about it, because that is simply what a bank account looks like when a business uses it. A company that exists only on paper, with a founder paying the AWS bill on a personal card abroad, has nothing to file.

The same logic runs through the rest of the file. The Ministry checks the applicant against its tax and social security record before paying, so the company has to be current with both. Store payouts and customer contracts should be in the company's name, because that is what shows the export is happening here rather than somewhere else. For a working business none of it takes any effort, because it describes what the business is already doing.

The other half of the question

There is a second version of this worry, and it deserves separating out. Founders are often less concerned with what Türkiye asks than with what their own tax office at home will say about a company they own abroad.

That is a fair question, it has good answers, and they depend on where you live and how the company is run rather than on Turkish law. We wrote about it separately in will my home country tax me anyway. The short version is that a company managed and staffed where it is registered is in a far stronger position than one that is not, which points the same way as everything above.

The part that pays you to do it

Türkiye does more than permit you to put people in the company. It pays for them.

Article 19 of the Decision covers the gross salary of staff hired for international promotion and marketing work:

• Up to five people in Türkiye, at 50% of gross salary and up to 90,000 TL of support per person per month. That is about $1,890 a month per person at roughly 47.7 TRY to the dollar, and at the 50% rate it covers a gross salary of 180,000 TL a month in full.
• Up to five more people in an overseas office, at up to 250,000 TL of support per person per month, about $5,240, covering a gross salary of 500,000 TL a month.

Each of those runs for five years. Filled to the cap, the Türkiye-based five are worth about $113,000 a year in cash back, and the overseas five about $314,000 a year. Companies on the Branding Programme get the same item for up to ten people instead of five.

Gross salary here means what it says: the payment to the person plus the tax and social security contributions attached to it, which is the number that leaves your account.

Two conditions matter. The person has to be hired into the company for the first time, and the first support claim has to come within six months of them starting. The item rewards building the team from here on, and an existing payroll does not qualify by looking backwards.

What substance costs

Take a studio that decides to do this properly and puts three people in Istanbul: someone running business development, a marketing manager, and an operations person who keeps the books, the payment trail and the filings in order.

At gross salaries of 180,000 TL a month for the first two and 120,000 TL for the third, the payroll runs to about 5,760,000 TL a year, roughly $121,000. The business development and marketing roles both qualify for salary support at 50%, which brings back 2,160,000 TL a year, about $45,000. The operations role does not qualify, because the item covers international promotion and marketing work rather than back office.

So the net cost of the local team is around $76,000 a year. Against that, those three people are the reason the company can claim on advertising, hosting, store commissions and everything else, which for a studio spending seriously runs to several hundred thousand dollars a year. The team pays for itself several times over before you count what it does for the business.

The salary support also runs for five years from the start, so it covers exactly the period when a new entity is least able to carry the cost.

What this adds up to

Nobody asks you to prove the company is real through paperwork. The programme is built so that a working business finds claiming easy and an empty shell finds it impossible, and then it pays for the hiring that puts you in the first category.

For most studios and SaaS companies moving here, the practical shape is a Turkish company that owns the product and bills the customers, a small local team it pays for, and founders who may or may not live in Istanbul. That is enough for the incentives, and it is a stronger position than a thinner setup would be with anyone else's tax authority.

If you want the numbers for your own case, the calculator covers the salary item alongside advertising, hosting and store commissions, and what the programme pays a studio walks through how the pieces fit together.