How Foreign AI Companies Access Türkiye’s Incentive Stack in 2026: From 0% Service Export Tax to App Store Commission Recovery

Foreign AI companies can access Türkiye’s full export incentive stack in 2026 without needing any AI-specific legislation. For foreign AI companies evaluating Türkiye, this is the central point: AI software development, generative AI products, machine learning platforms, and AI-powered SaaS already fall under the IT and software services category in Presidential Decree No. 10962. Add the 0% effective corporate tax brought by Law No. 7582 in June 2026, and the resulting cost picture is one that founders from San Francisco, Berlin, Tel Aviv, Singapore, and Bengaluru are increasingly running through their 2026 expansion models.

Tax Foundation for Foreign AI Companies: Law No. 7582 and 0% Effective Corporate Tax

The starting point for any foreign AI company evaluating Türkiye is the Türkiye Yüzyılı Tax Package, formally Law No. 7582, published in the Official Gazette No. 33270 on 4 June 2026 and applying retroactively from 1 January 2026. The amendment to Article 10/1-(ğ) of the Corporate Tax Code raised the deduction on qualifying service export income from 80% to 100%, bringing the effective corporate tax on qualifying revenues to 0%.

For AI companies, the qualifying conditions are straightforward and well-suited to typical AI business models:

• The provider must be a Türkiye-headquartered legal entity (LLC or joint stock company); 100% foreign ownership is permitted
• AI services — whether API calls, model access, SaaS subscriptions, or custom ML solutions — must be invoiced to a non-resident customer abroad
• Foreign currency proceeds must be repatriated to Türkiye through the Turkish banking system
• The activity must fall within qualifying NACE codes — typically NACE 62.01 (computer programming activities), 62.02 (IT consultancy), 62.09 (other IT services), or 63.11 (data processing, hosting and related activities)

For a deeper view of the tax framework, see our guide to the Türkiye tax reform and personnel subsidy.

The Atılım Program: Decree 10962 and Five Pillars for AI Companies

Atılım Program stack for foreign AI companies in Türkiye 2026 — five pillars under Decree 10962 by Proteşvik

Presidential Decree No. 10962, in force from 1 January 2026, brought IT, software, and digital services — AI products included — under a single export incentive framework run by the Ministry of Trade. For a foreign-owned Turkish entity exporting AI services, five support categories matter most in practice.

1. Digital Product Promotion Support — Up to 50 Million TL per Year

For each AI product (SaaS, mobile AI application, AI-powered web platform), foreign-currency advertising and marketing spend directed at international markets is reimbursable up to 50 million TL annually per product. Eligible expenses include Google Ads, Meta Ads, LinkedIn campaigns, App Store / Play Store advertising, programmatic display, influencer partnerships, and digital PR. The annual ceiling allows AI companies to scale international user acquisition without absorbing the full marketing burden.

2. Software Licensing Support (EK-31) — Critical for AI Cost Structures

The Software Licensing line item under EK-31 is one of the most relevant supports for AI companies. Eligible licenses and subscriptions include foundation model APIs (OpenAI, Anthropic, Google AI), cloud computing (AWS, Google Cloud, Azure), GPU compute, machine learning platforms (HuggingFace, Weights & Biases), MLOps tools, and vector database services. The annual ceiling is 2,500,000 TL per applicant, with 50% reimbursement (up to 70% for target countries) over a 5-year coverage period. Given that compute and API costs typically run between 30% and 50% of the operating expense base in the early growth phase, this support has a real effect on unit economics.

3. Database Membership Support (EK-19) — AI Training Data and Intelligence

Subscription fees for training datasets, market intelligence databases, sectoral data services, and analytical platforms are reimbursable under EK-19. The annual ceiling is 2,500,000 TL per applicant, at the same 50%–70% rate over 5 years. For AI companies that rely on high-quality data — financial market data, geospatial datasets, healthcare data, or specialized research databases — this is a recurring cost line that venture funding rarely covers efficiently, and the support closes part of that gap.

4. App Store and Google Play Commission Support — Up to 20 Million TL per Year per App

This is the support category that most directly addresses the structural cost burden faced by AI mobile applications: the 30% platform commission charged by Apple App Store and Google Play. Under Decree 10962, foreign-currency platform commissions paid for AI apps are reimbursable up to 20 million TL annually per app. For consumer AI applications operating on subscription models — generative AI assistants, image generation apps, AI writing tools, AI fitness coaches — recovering a meaningful portion of the platform fee fundamentally changes the LTV/CAC equation.

The same commission support extends to web-based payment processor fees (Stripe, PayPal, Adyen) for AI SaaS subscriptions sold to international customers — an aspect frequently overlooked in early-stage planning.

5. Marketing Personnel Subsidy — 90,000 TL Monthly per Domestic Hire

For AI companies hiring personnel in Türkiye for international marketing, business development, growth, and overseas market promotion, the marketing personnel subsidy reimburses 50% (up to 70% for target country activities) of gross salary up to 90,000 TL/month per personnel, for as many as 5 simultaneous hires, over a 5-year coverage period. For personnel placed in overseas branches or Star Technology Offices, the monthly ceiling rises to 250,000 TL.

The position title in the employment contract should align with the Ministry’s regulatory language. For a detailed breakdown of this support category, see our analysis of the personnel subsidy framework.

Beyond the Trade Ministry: Complementary Avenues for Foreign AI Companies

While the Ministry of Trade incentive architecture forms the operational core for foreign AI companies, two additional avenues are worth noting briefly:

TÜBİTAK 1711 Artificial Intelligence Ecosystem Call. The 2026 round of this program opened on 15 June 2026 with applications accepted until 18 September 2026, offering project budgets up to 10 million TL over 24 months in five priority areas (smart manufacturing, smart agriculture, financial technologies, climate sustainability, smart education). The structure requires a consortium of a Türkiye-resident company together with at least one Turkish university research laboratory or public research institute, which adds operational complexity for purely foreign-led structures but is achievable for entities with established Turkish partners.

Beyond TÜBİTAK, foreign AI companies establishing R&D operations may also evaluate technopark residency (Law No. 4691) for additional tax exemptions on qualifying R&D revenue — a complementary path our consultants evaluate case-by-case during the feasibility assessment.

Combined Annual Impact for a Foreign AI Company

The combined effect for foreign AI companies is easiest to see through a sample. Consider a foreign-owned Turkish entity running a mid-stage generative AI SaaS product: approximately USD 3 million in annual recurring revenue, USD 800,000 in annual compute and API costs, USD 1 million in annual marketing spend, and 3 domestic marketing personnel at the eligible ceiling. All figures below are annual (12-month period after activation) and use a USD/TRY exchange rate of 45.

The figures above are illustrative. Actual benefits depend on eligibility assessment, documentation quality, target country selection, product structure, and the company’s tax position in its home jurisdiction. The 2.5M TL annual ceilings for Software Licensing and Database Membership are revalued each January in line with the official Turkish revaluation rate, so 2027 ceilings will be higher than the figures shown. Independent local advice is recommended for the home-side calculation.

Three Illustrative Scenarios

Important note: The three scenarios below are fictional case studies created purely to make the regulatory framework concrete. Company names and financial figures are constructed for illustration. None represents an actual Proteşvik client.

Scenario A — NeuralForge AI (San Francisco): Generative AI API Platform

A Y Combinator-backed generative AI infrastructure startup based in San Francisco, USD 4 million annual revenue, serving developers globally. The founders establish a 100% US-owned Turkish LLC in Istanbul to host a portion of operations and route a share of international API revenue through the Turkish entity. They hire 4 local marketing and developer relations personnel.

• Tax saving on revenue routed through Türkiye: ~USD 800,000 annually under Law No. 7582
• Software Licensing + Database support: ~USD 50,000 annually (OpenAI, AWS, vector DBs)
• Marketing Personnel subsidy on 4 hires: ~USD 50,000–70,000 annually
• Combined estimated annual benefit: ~USD 900,000–920,000

Scenario B — Synapse Studio GmbH (Berlin): Consumer AI Mobile App

A Berlin-based consumer AI mobile application studio with USD 6 million in annual gross revenue (75% from in-app subscriptions on iOS and Android). The founders, facing approximately 30% effective home corporate tax burden and rising EU regulatory costs, establish a 100% German-owned Turkish LLC and shift marketing operations, user acquisition, and a portion of product development to the Turkish entity. They hire 5 local marketing personnel.

• Tax saving on qualifying revenue: ~USD 1.2 million annually
• App Store and Google Play commission recovery: ~USD 540,000 annually (significant portion of the 30% platform fee)
• Digital Product Promotion support on UA spend: ~USD 400,000 annually
• Marketing Personnel subsidy: ~USD 60,000–85,000 annually
• Combined estimated annual benefit: ~USD 2.2–2.3 million

Scenario C — Polymath AI Pte Ltd (Singapore): Enterprise AI SaaS

A Singapore-headquartered enterprise AI SaaS company serving Fortune 500 clients across APAC, EU, and MENA, USD 8 million in annual recurring revenue. The founders establish a 100% Singapore-owned Turkish LLC to anchor European and MENA market operations. They hire 3 marketing personnel in Türkiye and 2 in a newly established Star Technology Office in Dubai.

• Tax saving: ~USD 1.6 million annually under Law No. 7582
• Software Licensing + Database support: ~USD 80,000 annually
• Marketing Personnel subsidy (3 domestic + 2 overseas): ~USD 80,000–120,000 annually
• Combined estimated annual benefit: ~USD 1.76–1.8 million

12-Month Activation Roadmap

For a foreign AI company moving from interest to operation, a typical roadmap looks as follows:

• Months 1–2 — Strategic Assessment: company profile, revenue structure, product portfolio analysis; Turkish entity structure decision (LLC for the standard case); office location decision (Istanbul, Ankara, or technopark residency)
• Month 3 — Turkish Entity Setup: Turkish LLC incorporation in 1–2 weeks; minimum capital 50,000 TL (~USD 1,110); 100% foreign ownership permitted
• Months 3–4 — HİB Membership and DYS Activation: Services Exporters Association registration; Support Management System enrollment with e-signature; NACE code alignment
• Months 4–6 — Personnel Onboarding and First Applications: marketing personnel employment contracts drafted in line with Decree 10962 language; first Atılım Program applications (Digital Product Promotion, Software Licensing, Database Membership, App Store / Play Store Commission)
• Months 6–9 — Tax Exemption Activation: NACE code alignment, invoicing structure, and foreign currency repatriation protocols established; Law No. 7582 service export exemption activated
• Months 9–12 — First Reimbursement Cycle: documented eligible expenses submitted; initial reimbursement claims under the Takeoff Program

Frequently Asked Questions

Are foreign AI companies treated differently from other IT companies under Decree 10962?

No. There is no separate AI-specific category in current legislation. AI companies — whether building foundation models, applied AI products, generative AI applications, or AI-powered SaaS — are classified as IT and software service providers under qualifying NACE codes (typically 62.01, 62.02, 62.09, 63.11) and access the same incentive architecture as other software exporters.

Can a foreign AI company access the 0% effective tax without a Turkish entity?

No. The exemption under Law No. 7582 (KVK Article 10/1-(ğ)) is available only to Türkiye-headquartered legal entities. Foreign-owned Turkish LLCs qualify — 100% foreign ownership is permitted and no Turkish co-shareholder is required.

How does the App Store / Google Play Commission Support actually work?

The Turkish entity submits documented evidence of the 30% platform commission paid in foreign currency for each AI app distributed to international users. Up to 20 million TL annually per app is reimbursable. The support also extends to web payment processor fees for AI SaaS subscriptions sold internationally. HİB membership and a complete documentation file submitted through DYS are required.

What qualifies as an “AI product” for Digital Product Promotion support?

Any digital product where AI or machine learning is a meaningful component — including generative AI applications, conversational AI products, AI-powered SaaS, AI mobile apps, ML platforms, and AI infrastructure services. Each product is registered separately, and the 50 million TL annual ceiling applies per product (up to 10 products per applicant entity).

Can a company combine the tax exemption and the Atılım Program supports simultaneously?

Yes. Law No. 7582 (corporate tax exemption) and Decree 10962 (operational supports) operate under different legal anchors and can be claimed concurrently by the same Turkish entity, provided the qualifying conditions of each are independently met.

What is a typical reimbursement timeline under Decree 10962?

Once a complete file is submitted through the Support Management System (DYS), reimbursements typically arrive within 3–6 months, depending on file completeness and Ministry workload. Upfront funding is not required — the framework operates on a reimbursement basis against documented eligible expenses.

How Proteşvik Helps

Proteşvik offers a complimentary 30-minute feasibility assessment for foreign AI, SaaS, and tech companies considering Türkiye. The assessment covers:

• Eligibility analysis against Law No. 7582 and Decree 10962 — specific to your product and revenue structure
• Indicative annual combined benefit (tax exemption + Atılım Program supports)
• NACE code recommendation and entity structure guidance
• A concrete 12-month operational roadmap tailored to your AI business model

With more than 15 years of hands-on experience in Türkiye’s incentive ecosystem, our consultants translate the regulatory framework into operational outcomes. For the full scope of our work, see our consultancy services overview.

Official references:

• Resmî Gazete (Official Gazette)
• Ministry of Trade — Services Sector Supports
• Support Management System (DYS)
• Invest in Türkiye