Will my home country tax me anyway?

The question every founder asks before setting up in Türkiye. What controlled foreign company rules actually target, why a real operating business is treated differently from a shell, and the three questions to put to your adviser at home.

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A man on a phone call on a terrace above Istanbul rooftops The 0% IT tax regime

Every founder who reads about Türkiye's 0% tax on IT export income arrives at the same question within about a minute: fine, but will my own country still tax me on it?

It is the right question, and it has a good answer for most operating software businesses. Here is what actually drives it.

The Turkish side is settled

Under Article 10/1-(ğ) of the Corporate Tax Law, with the rate raised by Presidential Decision No. 11257 of 30 April 2026, the deduction on qualifying service export income is 100%, applying from 1 January 2026. Software, games and IT services invoiced to customers abroad and used abroad are deducted from the corporate tax base in full, which brings the effective rate on that income to 0%. Exported services are also VAT exempt.

That part does not depend on where you live. It is the position of the Turkish company.

What your home country might do about it

Most developed countries have some version of controlled foreign company rules. They let a country tax its own residents on profits made by a foreign company those residents control, rather than waiting for a dividend to be paid.

They exist for a specific reason. In the 1970s and 1980s people worked out that you could move a bundle of patents or a pile of cash into a company in a low-tax country, collect royalties and interest there, and never bring it home. CFC rules were written to stop that.

Which is why the thing they are aimed at is passive income in companies with no real activity. Interest, royalties, dividends, capital gains, sitting inside an entity that is a registered address and a bank account.

A game studio with forty people in Istanbul, an office lease, servers, an app store account and millions of paying players is not that. Most CFC regimes contain an exclusion for genuine active trading businesses, and an operating software company is the standard example of one.

The three questions

Take these to an adviser in your own country. They can usually answer all three in a single meeting.

1. Where am I tax resident? This is about you, not the company. If you are personally resident somewhere with CFC rules, they are potentially in play. If you move, they may not be.

2. Where is the company actually managed? Many countries look at where real decisions get made rather than where the company is registered. A Turkish entity with a Turkish managing director, staff who make operational decisions, and board meetings that happen in Istanbul is in a very different position from one run entirely by email from another country. This is something you decide, so decide it deliberately.

3. Does my country's regime exclude active business income, and what is the threshold? Most do exclude it. Many also apply an effective tax rate test. Your adviser will know both answers immediately.

Why Türkiye is a good answer to this problem

Substance is the thing every one of these rules turns on, and substance is expensive and awkward in most low-tax jurisdictions. You end up renting an office nobody sits in and importing staff who would rather be somewhere else.

Türkiye does not have that problem. There is a large and experienced games and software workforce here, salaries are competitive, and hiring twenty real people locally is a normal plan rather than a compliance exercise. Peak Games is the proof: a hundred people in Istanbul, running two of the biggest puzzle games in the world, sold for $1.8 billion.

So the substance that keeps you comfortable with your home country's rules is the same substance that makes the business work. You are not paying for a fiction.

There is also a second reason the numbers hold up. Alongside the tax position, Decision No. 10962 pays back 50 to 70% of what you spend growing abroad, in cash. That side of it is unaffected by anything your home country does with your corporate income, because it is a reimbursement of your costs rather than a tax rate on your profits.

What we do and what we do not

We handle the Turkish side completely: the entity, the tax position here, the accountancy, and every incentive claim. We do not advise on your home country's rules, because doing that properly requires a local specialist and there are a hundred and change of those countries.

What we can do is tell you exactly what the Turkish company looks like, so your adviser at home has something concrete to assess. That is usually all they need.

If you want the numbers first, the calculator shows what the incentive side is worth for your own spending, and the 0% regime covers the tax side in detail.

Frequently asked

What are controlled foreign company rules?

Rules that let a country tax its own residents on profits earned by a foreign company they control, without waiting for the money to be paid out as dividends. They exist to stop people parking passive income in a low-tax country while living somewhere else.

Does that mean Türkiye will not work for me?

For most operating software businesses it works well. These rules were built around passive income such as interest, royalties and dividends, and around companies with no real activity. A studio in Istanbul with employees, an office, servers and paying customers abroad is the opposite of what they were designed to catch. What matters is that the substance is genuine, and Türkiye is an unusually easy place to build it.

What actually decides it?

Three things. Where you are personally tax resident, where the company is really managed and controlled from, and what your home country's rules say about active trading income. The third is a question of local law, and the first two are things you can plan around deliberately.

Can you advise on my home country's rules?

No, and anyone who offers to across every jurisdiction is overselling. We handle the Turkish side end to end, including the entity, the tax position here and the incentive claims. For your home country you want a local adviser, and we are happy to work alongside them.

Is this a reason to delay?

It is a reason to ask three questions, not a reason to wait. Most founders get an answer in a single conversation with their adviser, and the answer is usually that a real operating company in Türkiye is fine.

Sources

https://cyberscope.solutions/blog/will-my-home-country-tax-me/ · Updated June 11, 2026 · CyberScope Solutions