Since 30 May 2025, state aid for investment in Türkiye has been governed by Presidential Decision No. 9903 on State Aid in Investments. It replaced the 2012 system; certificates issued under the old decisions continue under the rules they were issued under. Applications follow Communiqué 2025/1 and are filed on E-TUYS, the electronic system of the Ministry of Industry and Technology.
The decision has three layers: the Türkiye Century Development Initiative (the Technology, Local Development and Strategic programmes), sectoral support for Priority and Target investments, and regional support across six regions.
For a Chinese or Hong Kong company planning a plant in Türkiye, this decision and two tax laws (Law 7555 of 2025 and Law 7582 of 2026) decide how much of the machinery bill and of the future tax bill the state will share.
Rule one: apply before you spend
Decision 9903 is explicit: investment spending made before the date of the certificate application is not covered by the certificate (article 5(6)). Machinery bought before you apply stays outside the customs and VAT exemptions.
Other ground rules:
- Support only comes with a certificate, issued after the Ministry finds the project suitable on sectoral, financial and technical grounds.
- A minimum fixed investment applies. It is higher in regions 1 and 2 and is revalued every year, so we confirm the current figure for your project.
- Applications under the decision are accepted until 31 December 2030.
- Deadline 31 December 2026: for applications made by that date, two groups receive the support of region 6, which includes additional social security premium support: investments in the districts listed as affected by the February 2023 earthquakes, and manufacturing investments in organised industrial zones and industrial zones of the former attraction-centre provinces (not those whole provinces).
What a certificate can give a manufacturer
Depending on the programme and region, a certificate can bring:
- Customs duty exemption on imported machinery and equipment.
- VAT exemption on imported and locally purchased machinery and equipment, and on software and intangible rights listed in the certificate.
- Reduced corporate tax (explained below).
- Interest or profit-share support, machinery support, land allocation and, under the regional layer, employer social security premium support.
How the reduced corporate tax works
Each programme has a contribution rate. The contribution amount is that percentage of the eligible investment, and it caps the total tax saving.
| Programme | Contribution rate |
|---|---|
| Technology Initiative, Local Development Initiative | 50% |
| Strategic Initiative | 40% |
| Priority investments | 30% |
| Target investments | 20% |
Until the contribution amount is used up, corporate tax on profits from the certified investment (and, within limits, on the company’s other profits) is charged at a rate reduced by 60%, which is 10% instead of the general 25%. Since Law 7555 (Official Gazette, 24 July 2025), this applies for at most ten accounting periods, counting the first period in which the reduction can be used. The rule covers certificates obtained from the date that law was published; applications filed before 16 June 2025 and not rejected stay under the earlier rules.
Contribution amounts left unused in a profitable year cannot be carried to later years. So the real saving depends on the profit your Turkish company makes within those ten periods.
From 2027: a 12.5% rate for manufacturing profits
Law 7582 (Official Gazette, 4 June 2026, No. 33270) rewrote article 32(8) of the Corporate Tax Law. The conditions are precise:
- Who: companies that hold an industrial registry certificate (sanayi sicil belgesi) and are actually engaged in production. Agricultural producers qualify for their production profits too.
- Which profits: only profits derived from those production activities. Other income, such as trading profits or interest, does not get the 12.5% rate.
- From when: profits of 2027 and later periods; for a special accounting period, the period beginning in calendar year 2027.
- No stacking: profits taxed at 12.5% cannot also use the 5-point reduction for export earnings.
You may have read about lower rates for exporters announced in April 2026. As of 16 October 2026 we have not seen them enacted: the law still provides the 5-point export reduction.
The 10% domestic minimum corporate tax also matters. Tax not collected because of the 12.5% rate is deducted when that minimum is computed; for certificates, the law gives this treatment only to contribution amounts from certificates obtained before 2 August 2024. New companies are exempt from the minimum tax for their first three accounting periods.
Very large projects: a direct contract with the Ministry
Under the project-based support system, the Minister may sign a private-law investment contract with foreign investors for a completely new project of at least TRY 5 billion. This power has existed since 2019. Decision 11572 (Official Gazette, 9 August 2026, No. 33335) extended it to Turkish subsidiaries wholly owned by those investors, so the local company can now be the party itself.
The same decision tightened the conditions:
- Applicants need a protocol with a development or investment bank and a feasibility report in the prescribed format.
- Within three years of the support decision, the investor must prove spending of TRY 200 million or 10% of the planned investment; otherwise the decision is revoked, unless force majeure or extraordinary circumstances prevented the start.
- An annual activity report is due for five years after the completion visa.
Groups above €750 million: check the global minimum tax
If your group’s consolidated revenue exceeded €750 million in at least two of the four preceding years, Türkiye’s global minimum tax rules apply. A reduced rate under a certificate, and from 2027 the 12.5% rate, can bring the Turkish effective tax rate below 15%. Türkiye can then collect the difference first, through its own domestic top-up tax. The relief under the domestic minimum tax has no equivalent in these global rules.
The OECD’s Side-by-Side package of 5 January 2026 includes a safe harbour for substance-based incentives, but we have not seen Turkish legislation adopting it as of 16 October 2026. For a large group, the value of an incentive is what remains after this test. Background: global minimum tax for Chinese and Hong Kong groups.
Why the local company comes first
The benefits attach to the certificate holder: the VAT exemption applies to its purchases, and the reduced corporate tax is applied in its Turkish corporate tax returns. The 12.5% rate also requires the producing company to hold the industrial registry certificate. For a foreign group, this is normally the Turkish company.
There are bookkeeping consequences too. Since 1 January 2026, goods and services bought in Türkiye under a certificate must be invoiced as an e-invoice or e-archive invoice. When the investment is finished, a completion visa closes the certificate.
What this means for you
- Do not sign or pay for machinery before the application. Build the certificate into your project timetable.
- Prepare a project outline: product, location, capacity, timetable, and an investment budget that separates buildings, imported and domestic machinery, and software.
- Set up the Turkish company early. See company formation. Founders who will not travel can use the power-of-attorney route (formation with power of attorney): USD 3,000 for the complete formation without a package, or the full USD 3,000 on top of the Professional package. Prices exclude VAT: no VAT for clients invoiced outside Türkiye; 20% VAT is added for clients in Türkiye.
- Large groups: test the incentive against the 15% global minimum tax before relying on the headline rate.
Our investment incentives service covers the eligibility review, the E-TUYS application, use of the exemptions in your books and tax returns and the completion visa; the fee is quoted per project after the review. Where a sworn financial adviser (YMM) report is required, you engage a YMM and pay the YMM’s fee separately; we can recommend one.
You can write to us in Chinese or English: WeChat ID etitax, e-mail info@etitax.com, WhatsApp +90 532 061 99 83 (it may not be reachable from mainland China; WeChat or e-mail works better there), office +90 442 213 94 04. Or use our contact page.
