Certification Services for Income and Corporate Tax Exemptions, Deductions, and Applications
In accordance with the General Circular on the Law on Certified Public Accountants and Sworn-in Certified Public Accountants (Serial No. 49) published in the Official Gazette dated 30 December 2025, certain tax exemptions, deductions, and the application of Domestic and Global Minimum Supplementary Corporate Tax (Pillar Two) regulations are subject to mandatory certification by a Sworn-in CPA.
Under the relevant Communiqué, Sworn-in CPA Certification Reports must be submitted for exemption and deduction amounts exceeding the prescribed monetary thresholds and reported in the annual Income Tax and Corporate Tax returns. Certification requirements also apply to transactions arising from Domestic and Global Minimum Supplementary Corporate Tax calculations and applications.
Our certification services are designed to support taxpayers in meeting statutory compliance requirements while mitigating tax risks. Services include:
- Assessing the eligibility of exemptions and deductions in line with applicable tax legislation
- Reviewing calculation methodologies, supporting documentation, and data integrity
- Auditing compliance with Domestic and Global Minimum Supplementary Corporate Tax rules
- Preparing and submitting Sworn-in CPA Certification Reports in accordance with legal and administrative guidance
The scope of exemptions and deductions subject to certification is determined based on the provisions of the Communiqué and related secondary legislation. Timely and accurate fulfillment of these obligations is critical to ensure compliance and to avoid potential tax assessments, penalties, and disputes.
Accordingly, transactions related to exemptions, deductions, and applications that exceed statutory thresholds and are included in annual income and corporate tax returns must be certified by a Sworn-in CPA.
Within this context, income tax taxpayers, pursuant to Income Tax Law No. 193 and other relevant legislation, are required to have the following exemptions, deductions, and applications included in their annual income tax returns certified by a Sworn-in Certified Public Accountant:
| Exemption / Deduction / Application | Relevant Legislation |
| 1- Exemption on Industrial Property Rights | Law No. 5520 (Article 5/B) |
| 2- Exemption on Profits from the Operation and Transfer of Ships Registered in the Turkish International Ship Registry | Law No. 4490 dated 16/12/1999 and the Decree Law No. 491 on Amendments |
| 3- Exemption on Profits Earned in Free Zones | Law No. 3218 dated 6/6/1985 |
| 4- Exemption on Profits Earned in Technology Development Zones | Law No. 4691 dated 26/6/2001 |
| 5- Deduction on Profits from Software, Engineering, Education, and Health Services Provided Abroad | Law No. 193 (Article 89/13) |
| 6- Reduced Income Tax Application | Law No. 5520 (Article 32/A) |
| 7- R&D and Design Deductions | Law No. 5746 dated 28/2/2008 on Supporting Research, Development, and Design Activities |
| 8- Investment Allowance Exemption (for those not subject to withholding under Temporary Article 61 of Law No. 193) | Law No. 193 |
| 9- “Other Deductions” in the “Deductions from Income to be Declared” Section and “Other Exemptions” in the “Notification on Exempted Profits” Section of the Annual Income Tax Return | Law No. 193 and other laws |
| Exemption / Deduction / Application | Relevant Legislation |
| 1- Exemption on Foreign Subsidiary Profits | Law No. 5520 (Article 5/1-b) |
| 2- Exemption on Profit from Sale of Foreign Subsidiary Shares | Law No. 5520 (Article 5/1-c) |
| 3- Exemption on Share Premium Profits | Law No. 5520 (Article 5/1-ç) |
| 4- Exemption on Profits of Real Estate Investment Funds or Partnerships (excluding those established to operate portfolios consisting mainly of real estate, real estate projects, and real estate-based rights) | Law No. 5520 (Article 5/1-d) |
| 5- Exemption on Profit from Sale of Immovables, Subsidiary Shares, Founders’ Shares, Enjoyment Shares, Pre-emptive Rights, and Venture Capital Fund Participation Shares | Law No. 5520 (Article 5/1-e and Temporary Article 16) |
| 6- Exemption on Profits from Construction, Repair, Assembly, and Technical Services Abroad | Law No. 5520 (Article 5/1-h) |
| 7- Exemption on Industrial Property Rights | Law No. 5520 (Article 5/B) |
| 8- Exemption on Profits from the Operation and Transfer of Ships Registered in the Turkish International Ship Registry | Law No. 4490 |
| 9- Exemption on Profits Earned in Free Zones | Law No. 3218 |
| 10- Exemption on Profits Earned in Technology Development Zones | Law No. 4691 |
| 11- Exemption on Profits Earned by Research Infrastructures from R&D and Innovation Activities | Law No. 6550 dated 3/7/2014 |
| 12- R&D Deduction | Law No. 5520 (Repealed Article 10/1-a) |
| 13- Deduction on Profits from Software, Engineering, Education, and Health Services Provided Abroad | Law No. 5520 (Article 10/1-ğ) |
| 14- Deduction on Interest from Cash Capital Increase | Law No. 5520 (Article 10/1-ı) |
| 15- Reduced Corporate Tax Rate Application | Law No. 5520 (Articles 32/6,7,8 and Article 32/A) |
| 16- Domestic and Global Minimum Top-up Corporate Tax Application | Law No. 5520 (Additional Articles 1–13 and Temporary Article 17) |
| 17- R&D and Design Deductions | Law No. 5746 |
| 18- Technological Capital Support Deduction | Law No. 5746 |
| 19- Technopark Capital Support Deduction | Law No. 4691 |
| 20- Investment Allowance Exemption (for those not subject to withholding under Temporary Article 61 of Law No. 193) | Law No. 193 |
| 21- “Other Deductions and Exemptions” in the “Deductions and Exemptions to be Applied Even in Case of Loss” Section and “Deductions and Exemptions to be Applied in Case of Profit” Section of the Annual Corporate Tax Return | Law No. 5520 and other laws |
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Adress
Maslak Mah Ahi Evran Cad
42 Maslak
Multi Office A No: 14/03
Sarıyer / İstanbul Türkiye
Working Hours
Monday – Friday: 09:00 – 18:00 Saturday – Sunday: Closed
Contact
denetim@tandenetim.com +90 212 812 74 19