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Tax · Foreign-owned companies

Taxes for foreign owners of a Turkish company

The basic rule is simple: a company set up in Turkey is a Turkish company subject to Turkish tax law, whatever the nationality of its shareholders. The differences for a foreign shareholder arise when profits are distributed abroad and taxed in the shareholder's own country.

Türkçe

Short answer

How are a foreign-owned Turkish company and its shareholders taxed?

A company established in Turkey is subject to Turkish tax law regardless of its shareholders' nationality. Corporate profits are taxed at the general corporate tax rate of 25%. From 2025, the tax calculated may not be lower than 10% of profit before deductions and exemptions. Dividends distributed to a foreign shareholder are subject to 15% withholding tax, which may be reduced under the double tax treaty with the shareholder's country.

Taxes at company level

TaxRate or ruleLegal basis
Corporate taxGeneral rate 25%Corporate Tax Law Art. 32 (Law No. 7456)
Domestic minimum corporate taxTax calculated may not be less than 10% of profit before deductions and exemptions (2025 onwards)Corporate Tax Law Art. 32/C (Law No. 7524)
Advance taxPayments during the year on periodic profitsCorporate and Income Tax Laws
VATCharged on sales, deducted on purchasesVAT Law
Payroll taxesIncome tax and stamp duty on staff salariesIncome Tax Law, Stamp Duty Law

The corporate tax rate may differ for certain sectors and transactions. Current rates should be checked in the table published by the Turkish Revenue Administration (GİB).

Dividend distribution: 15% withholding

When after-tax profit is distributed, dividend withholding tax applies. Under Presidential Decree No. 9286, the rate has been 15% since 22 December 2024. It also covers distributions to individuals and companies resident abroad.

Example (no tax treaty applied)Amount
Dividend distributed to the foreign shareholderTRY 1,000,000
Dividend withholding tax (15%)TRY 150,000
Net amount paid to the shareholderTRY 850,000

Double tax treaties

Turkey has double tax treaties with many countries. These may set a lower maximum rate for dividend withholding than domestic law. To apply the treaty rate, the following are usually required:

  • the foreign shareholder is resident in the treaty country,
  • a certificate of residence proving this is submitted,
  • the treaty's other conditions (for example a minimum shareholding) are met.

Rates and conditions differ from treaty to treaty, so the treaty with the shareholder's country should be reviewed before distribution. Whether tax paid in Turkey can be credited in the shareholder's own country depends on that country's law.

Other payments between the company and its shareholders

Salary

A salary paid to a foreign shareholder who actually works in the company goes through payroll. Whether the shareholder is a Turkish resident determines whether they are a full or limited taxpayer and the scope of taxation. A work permit is also required to work in Turkey.

Shareholder loans

Loans from shareholders or related companies are subject to the thin capitalisation and transfer pricing rules of the Corporate Tax Law. The amount, interest rate and agreement should be set within these rules.

Related-party transactions

For services, licences and management fees charged by group companies, the arm's-length nature of the price must be documented. Some service and licence payments made abroad may also be subject to withholding tax.

Checklist

  1. Are corporate tax and the domestic minimum corporate tax being calculated?
  2. Has the tax treaty with the shareholder's country been reviewed before distributing profits?
  3. Has a certificate of residence been obtained?
  4. Are payments to shareholders correctly classified as salary, dividend or loan?
  5. Is the arm's-length nature of related-party transactions documented?

Frequently asked questions

How is a double tax treaty applied to dividends?

If the treaty provides a lower withholding rate for dividends, the foreign shareholder usually has to submit a certificate of residence from the treaty country. Rates and conditions differ in each treaty.

How is a foreign shareholder taxed if they work in the company?

Salary paid to a shareholder who works in the company is subject to income tax through payroll. Whether the shareholder is a full or limited taxpayer in Turkey depends on their residence. A work permit is also required to work in Turkey.

Does borrowing from shareholders cause tax problems?

Loans from shareholders or related parties are subject to thin capitalisation and transfer pricing rules in the Corporate Tax Law. The amount, interest rate and documentation should be assessed under these rules.

Official sources (in Turkish)

  1. 01Kurumlar Vergisi OranlarıGelir İdaresi Başkanlığı · Son kontrol: 27 Eylül 2026
  2. 027524 sayılı Kanun ile getirilen yurt içi asgari kurumlar vergisi (KVK m. 32/C, RG 02.08.2024)KPMG Vergi bülteni (ikincil kaynak) · Son kontrol: 27 Eylül 2026
  3. 039286 sayılı Cumhurbaşkanı Kararı — kâr payı stopaj oranının %15'e çıkarılması (RG 22.12.2024)Resmî Gazete · Son kontrol: 27 Eylül 2026
  4. 044875 sayılı Doğrudan Yabancı Yatırımlar KanunuMevzuat Bilgi Sistemi · Son kontrol: 27 Eylül 2026

This page is based on our Turkish content, which is checked against official Turkish sources. If there is any difference, the Turkish legislation prevails. General information only. Laws and practice change; get professional advice on your specific situation before acting.

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