The provision covers two activities: buying and selling abroad on the company’s own account, and brokering a purchase and sale between two parties located abroad. In both, the decisive fact is that the goods never enter Türkiye.

The Communiqué sets five conditions. All of them must be met together.

• 01The income must arise from selling goods purchased abroad without bringing them into Türkiye, or from brokering a purchase and sale of goods taking place abroad.
• 02In brokerage, neither the seller nor the buyer of the goods may be located in Türkiye.
• 03The income must be transferred to Türkiye by the date the annual corporate income tax return is due for the accounting period in which it was earned.
• 04Companies operating in the Istanbul Finance Centre Zone must hold a participant certificate under Law No. 7412.
• 05For companies in industrial zones, the zone must be one approved by the President on the basis of foreign investment density.

The single test that sets the boundary is whether the goods become the subject of any disposition in Türkiye.

The Communiqué also addresses two categories beyond physical goods. The test is the same in both: what was acquired must be sold on unchanged and without being used in Türkiye.

Intangible rights

Copyrights, trademarks, patents, utility models, industrial designs, licences, broadcasting rights and similar intangible rights acquired from persons or entities resident abroad also qualify, where they are sold on directly to persons or entities resident abroad in the form acquired — without modification and without being used by anyone resident in Türkiye, including the acquirer itself — or where such transactions are brokered.

Calculating the deduction

Costs and expenses incurred for the qualifying activities are deducted from the revenue those activities generate. Of the remaining income, 95% — or 100% for the Istanbul Finance Centre Zone and approved industrial zones — is claimed under the “Exemptions and Deductions to Be Applied If There Is Income” section of the corporate income tax return.

• No carry-forward. Any amount that cannot be deducted because of other deductions, exemptions or prior-year losses may not be carried forward to subsequent periods.
• No deduction against a loss. Where the activity results in a loss, no deduction arises.

Tracking the income in the books

Revenue, cost and expense items that fall within the scope of the deduction must be tracked separately from those that do not; items belonging to qualifying activities must not be associated with other activities, and the books must be kept in a way that maintains this separation. Taxpayers operating in the Istanbul Finance Centre Zone must keep books and comply with documentation and record-keeping rules under the general provisions of the Tax Procedure Law.

Income outside the main activity

Income of a company benefiting from the deduction that falls outside the qualifying activities — such as interest earned on cash balances, foreign exchange differences arising from the valuation of currency, and gains on the disposal of assets — together with extraordinary income, cannot be treated as within the scope of the deduction.

This note is for general information. It is based on section 10.7 of Corporate Income Tax General Communiqué No. 1, as redrafted by the amendment published in the Official Gazette of 4 July 2026, No. 33300. Turkish statutory terms are given in parentheses where a precise reference matters. Before acting, confirm the current text of the legislation and your company’s specific position with your sworn-in certified public accountant.