On 28 December 2023, the Revenue Administration of Turkey announced that it had published Law No. 7491 in the Official Gazette.
The main provisions are as follows:
- New participation exemption rules have been implemented for corporate taxpayers who do not meet the standard participation exemption criteria for stakes in joint stock corporations and limited liability companies outside of Turkey. Under these rules, a 50% exemption is granted on dividend income from a foreign company if the taxpayer holds a minimum of 50% of the foreign company’s paid-up capital and the dividend income is repatriated to Turkey by the corporate tax return filing deadline for the relevant period.
- The corporate tax deduction for income derived from exporting specific services to non-residents solely utilized abroad has been raised from a 50% deduction to an 80% deduction on the condition that all earnings must be transferred to Turkey. This applies to services such as engineering, architecture, design, software development, accounting, data storage, call center operations, education, and health services.
- The 5% tax rate reduction or discount in the corporate tax rate for export income has been expanded. It now includes income from manufacturing or supplying companies engaged in export activities through foreign trade capital or sectoral foreign trade companies under an intermediary export contract.
- Social media content creators are eligible for tax exemptions and now include earnings from sharing text, images, videos, and audio content on websites or any digital platform.
The Law No. 7491 came into effect on 28 December 2023. However, different tax measures have various effective dates. The 50% participation exemption, the 80% deduction on export service income, and the increased 5% discount for income derived from exports go into effect on 1 January 2023. Changes related to social media will apply from 1 January 2024.