SYSTEMS CPA · Industrial Registry & 2027 Compliance · Reviewed 27 October 2026

Contract Manufacturing in Turkey: Who Holds the Industrial Registry Certificate?

International companies often have a Turkish subsidiary that contracts a third-party factory, owns the brand and sells the resulting product. This commercial arrangement does not automatically make the brand owner a registered industrial producer.

Identify the actual production enterprise

Start by mapping the physical production site, machinery, personnel, technical process and which business performs the manufacturing steps. The operator of the production activity and its registered workplace will generally have a different position from a party merely buying finished goods. Contract wording alone cannot replace examination of the real production model.

Three common structures

1. Contractor manufactures; brand owner buys goods: the contractor’s actual industrial operation and certificate are examined separately from the brand owner’s purchase-and-resale margin.
2. Subsidiary operates its own manufacturing line: check that entity’s own registration and capacity information for its Turkish production location.
3. Mixed operation: one legal entity both manufactures and trades imported or contracted-out goods. Industrial registry may be relevant to its own activity, but profits need segregation.

2027 tax analysis: profit follows the actual activity

The amended Corporate Tax Law Article 32(8) refers to institutions that hold a certificate and actually conduct production, with the 12.5% rate only on exclusively production-derived profits. It should not be applied to all brand-owner revenue merely because products carry a ‘Made in Turkey’ label or because a supplier holds a certificate. Related-party and transfer-pricing analysis can also affect the allocation of margins.

Documents to assemble

Manufacturing and supply agreements, invoices, description of the production process, facility lease or ownership information, staff and machinery position, intellectual-property arrangements, inventory movement and evidence of who performs the activity. Treat private agreements as confidential: the first contact should be a high-level description only.

How SYSTEMS CPA helps

We can map the legal entity and the manufacturing function, identify which certificate or capacity evidence is relevant, and outline the accounting controls needed to support 2027 tax positions. The competent authority determines actual registration eligibility.

Related: benefits and conditions and tax timing explained.