Free Zone Company Accountant in Turkey: What Should the Monthly Fee Cover?

Key facts at a glance

What should a free zone company accountant in Turkey cover for the monthly fee?

An accountant’s monthly fee for a free zone company in Turkey should cover bookkeeping and e-ledger, the monthly withholding and social security return, payroll and SGK notices, reconciliation of free zone transaction forms and tracking of the payroll exemption. Annual corporate tax work, sworn CPA (YMM) certifications, transfer pricing reports, audits and parent-company packages are often priced separately, so confirm each line in writing.

Most proposals for free zone companies go wrong in the same place: they price “monthly accounting and tax” as if the client were an ordinary trading company in Istanbul. Free zone tax rules are national, so they apply in the same way in DESBAŞ in Tuzla, the Aegean Free Zone in Izmir or the Mersin Free Zone. What changes from file to file is the amount of work those rules create.

The table splits that work into the blocks that should appear in any proposal. The right-hand column is the question to put to every firm you are comparing.

If you are comparing proposals now, the brief further down lists the ten facts any firm needs to quote on a like-for-like basis.

Manufacturer vs trader: which free zone profits are exempt from corporate tax?

Only production users get the main exemption. From 1 January 2026, profits from goods produced in a Turkish free zone and sold abroad, within the same zone or to another free zone are exempt from corporate tax under Law No. 3218, Provisional Article 3. Profits from sales into Turkey are taxable, and trading, warehousing and leasing profits are taxed under the general rules.

The rule has moved twice in two years. Law No. 7524 (Official Gazette, 2 August 2024) limited the exemption to sales abroad from 1 January 2025. Law No. 7577 (Official Gazette, 17 April 2026) widened it again, for profits from 1 January 2026, to sales inside the same zone and to other free zones. The Ministry of Trade announced the change on 11 May 2026, and Corporate Tax General Communiqué Serial No. 26 added worked examples in July 2026. Pages written before April 2026 often still describe the export-only rule.

Notes: 2025 remains open to tax examination, and Revenue Administration rulings for 2025 treated sales to free zone buyers as outside the export-only exemption. Licences obtained on or before 6 February 2004 keep the rights attached to the first paragraph of Provisional Article 3 for the licence term.

What else is in, and what stays out

• Listed services. Since 2017 (Law No. 6772), profits from maintenance, repair, assembly, disassembly, handling, sorting, packaging, labelling, testing and storage are exempt where the whole service is provided to non-residents and the goods are sent abroad without entering Turkey.
• Outside the exemption. Profits from goods produced outside the zone, outside the area named in the operating licence or by contract manufacturers (fason), and profits from trading in purchased goods.
• Separate records. The books must allow exempt and non-exempt profits to be determined separately, with shared costs allocated between them.
• Minimum tax. The 10% domestic minimum corporate tax that applies from 2025 (Corporate Tax Law Art. 32/C) allows the free zone exemption to be deducted from its base. A newly established company is outside the minimum tax for its first three accounting periods.
• Certification. Under General Communiqué No. 49 (Official Gazette, 30 December 2025), a corporate taxpayer claiming the free zone exemption above TL 500,000, or listed exemptions above TL 1,000,000 in total, must support the claim with a sworn CPA (YMM) certification report. The thresholds are updated each year.

Exempt profits vs exempt payroll: how the 85% test works

Wages paid by a free zone manufacturer are exempt from income tax only if the company exports at least 85% of the FOB value of the goods it produces in the zone. The tax is calculated and deferred every month, then written off once a sworn CPA (YMM) report confirms the export ratio. Social security premiums are paid in full regardless.

The 2026 change created a mismatch. Law No. 7577 amended only the corporate tax limb in paragraph 2(a). The payroll limb in paragraph 2(b) still counts exports abroad. Under Free Zones General Communiqué No. 1, sales inside the zone and into Turkey stay in the total FOB value of production but do not count as exports. A manufacturer can therefore keep its corporate tax exemption on zone-to-zone sales and still fail the payroll test.

There is one bridge. A delivery to an exporter in the same or another free zone, made on condition that the goods are exported, counts as a foreign sale for the producer if the goods leave for abroad within three months from the start of the month after delivery. The exporter cannot then count the same goods towards its own exemption.

The monthly and year-end mechanics

1. Every month: payroll calculates income tax on wages under the normal rules and declares it on the withholding and social security return, together with the notifications the Communiqué requires. The tax office accrues the tax and defers it (tecil) instead of collecting it.
2. Every month: SGK premiums are calculated and paid in full. The exemption does not reduce social security.
3. Through the year: production quantities, sales by destination and export evidence (customs exit declarations or Free Zone Transaction Forms) are tracked product by product.
4. After year-end: the FOB value of zone-made goods exported abroad is compared with the total FOB value of zone-made goods, using the averaging and first-in, first-out rules the Communiqué sets for stock carried between years.
5. If the ratio is 85% or more: a sworn CPA issues the Free Zone Activity Certification Report (Serbest Bölge Faaliyet Tasdik Raporu), and the tax office writes off (terkin) the deferred tax.
6. If it is below 85%: the deferred tax is collected with late-payment interest (gecikme zammı), without a tax penalty.

The exemption does not cover wages for periods when an employee works outside the zone, or wages paid by users whose activity is trading or services rather than production. Where a company has more than one activity, only wages declared for the production workplace qualify. Goods bought in and re-exported are left out of the calculation entirely.

Will your accountant charge Turkish VAT to a free zone company?

Usually, yes. Under VAT Law Article 17/4-ı, only services actually performed inside a free zone are exempt. Services supplied to a zone company from an office in Turkey outside the zone, such as monthly accounting and payroll, are subject to Turkish VAT at the standard 20% rate. Contract-manufacturing (fason) services for free zone customers have a separate exemption.

The Revenue Administration’s VAT General Implementation Communiqué (section II/F-4.9) states that services supplied from Turkey into a free zone, and from a zone into Turkey, are taxable, and that services supplied from Turkey to free zones are not service exports. VAT Circular No. 60 adds that services performed inside the zone are exempt whether or not the provider holds a free zone licence. Goods are different: a delivery from Turkey to a buyer in a free zone is an export delivery and is exempt under VAT Law Articles 11/1-a and 12.

For the budget, the point is recoverability. Most of a free zone company’s own sales sit outside Turkish VAT, and many zone companies are not regular VAT taxpayers. For them, VAT on a Turkish supplier’s invoice is usually a cost, not an input they can recover. That is why finance teams in free zones often ask for fees “inclusive of VAT”. Compare proposals on that basis, and ask the accountant to confirm in month one which VAT returns, if any, the company must file.

The free zone layer: transaction forms, licence scope and records

Every movement of goods into, out of and within a Turkish free zone is recorded on a Free Zone Transaction Form (Serbest Bölge İşlem Formu) through the Ministry of Trade’s free zone software (SBBUP). The accountant should reconcile those forms with invoices, stock and customs data every month, because both the corporate tax exemption and the 85% payroll test are computed from them.

• Books regardless of size. For accounting periods starting after 31 December 2004, every business in a free zone keeps books under the Tax Procedure Law (Free Zones Implementing Regulation, Article 23, as applied by the Revenue Administration). A company with no revenue yet still has full bookkeeping and filing duties.
• Licence scope. The operating licence names the activities the company may carry out, and the exemption follows the licence. The Ministry of Trade’s information note (May 2026) gives licence terms of 20 years for production and 15 years for other activities for tenant users, and 45 and 30 years for investor users who build their own premises.
• Sales into Turkey. Goods leaving the zone for Turkey enter free circulation under import procedures. The same Ministry note states that production users pay a Special Account fee of 0.9% of the FOB value on these shipments. The profit on them is taxable.
• Other reliefs. Zone-related transactions are exempt from fees and their documents from stamp duty (Provisional Article 3(2)(c)); the Ministry note adds a property tax exemption for buildings a user owns and uses itself.

None of this depends on which zone you choose. Operator tariffs, rents and service charges differ by zone; the tax rules do not. Our comparison of free zones in Turkey covers the commercial side.

Turkish statutory books vs head-office reporting: two sets of numbers from one ledger

Turkish statutory books follow the Tax Procedure Law and the uniform chart of accounts, while the parent consolidates under IFRS, Ind AS or another framework. A free zone company can narrow the gap in two ways: it may keep its statutory books in a foreign currency such as USD or EUR, and it can apply for a 12-month special accounting period that matches the parent’s year.

Can a free zone company keep its books in USD or EUR?

Yes. Section 4 of Tax Procedure Law General Communiqué No. 348 allows a business operating in a free zone to keep its books in any foreign currency for which the Central Bank of the Republic of Turkey sets a daily rate. The option is not available to a free zone branch of an onshore Turkish company, or to an onshore branch of a free zone company. The currency is chosen for a whole accounting period: in a recent ruling, the Istanbul tax administration told a company that had kept its e-ledger in euros on a 1 October–30 September year that it had to return to Turkish lira from the start of the period after its zone activity ended.

Can the Turkish year match the parent’s year?

The calendar year is the default under Tax Procedure Law Article 174, but the Ministry can grant a 12-month special accounting period (özel hesap dönemi) on application where the calendar year does not suit the business. Aligning with a parent’s consolidation calendar is the most common reason in foreign-owned groups. Profits of a special period are treated as income of the calendar year in which the period ends, and the corporate tax filing date moves with the period.

What a usable parent package looks like

• A monthly close calendar fixed in the engagement letter, with the day the management pack is due.
• A mapping from the Turkish chart of accounts to the group chart, maintained every month rather than rebuilt at year-end.
• Intercompany balances reconciled monthly with the parent and sister companies.
• English year-end statements and notes, reconciled to the Turkish statutory figures.

Our CFO guide to Turkish statutory accounting vs IFRS lists the adjustments that usually sit between the two, and our management reporting service shows what a monthly pack contains.

If your parent company is in India: APR, audit and the April–March year

An Indian company with a Turkish subsidiary must file an Annual Performance Report (APR) through its authorised dealer (AD) bank by 31 December each year. Where the Indian parent controls the subsidiary, the APR must be based on audited financial statements, even if Turkish law does not require the subsidiary to be audited.

The obligation comes from Rule 23 of India’s Foreign Exchange Management (Overseas Investment) Rules, 2022, Regulation 10 of the Overseas Investment Regulations, 2022, and the Reserve Bank of India’s Master Direction on overseas investment. The RBI’s APR form allows unaudited statements only where the Indian investor does not have control and the host country does not make an audit mandatory. A wholly owned subsidiary fails the first condition.

In Turkey, a newly established company is usually below the independent-audit thresholds set under Turkish Commercial Code Article 397, so it has no statutory audit. The parent will still need an audit for the APR. Most AD banks expect it to be signed by a licensed auditor in the host country; in Turkey, statutory audits are performed by auditors authorised by the Public Oversight, Accounting and Auditing Standards Authority (KGK), and using one for a voluntary audit avoids questions at the bank.

What the Indian side typically asks the Turkish accountant for

• Monthly management accounts in English, on the parent’s close calendar.
• A 31 March reporting package for consolidation under Ind AS or Indian GAAP, unless the subsidiary has a special accounting period ending on 31 March.
• Audit-ready year-end statements and support for the auditor’s queries.
• Figures and reconciliations for the APR and for the parent’s annual Foreign Liabilities and Assets (FLA) return.
• Confirmations the AD bank asks for, such as paid-in capital and shareholding.

Transfer pricing: what a free zone company must document

A free zone company must price related-party transactions at arm’s length under Corporate Tax Law Article 13. Its annual transfer pricing report must cover related-party transactions with companies inside Turkey as well as cross-border ones, must be ready by the corporate tax return deadline and must be produced on request. The transfer pricing form is filed with the return.

Article 19(4) of the transfer pricing decision (Decision No. 2007/12888) lists who prepares the annual report. Ordinary corporate taxpayers outside the large-taxpayer office document their cross-border related-party transactions; free zone corporate taxpayers must also document their related-party transactions inside Turkey. The reason is plain once the exemption is understood: profit moved from an onshore affiliate into an exempt zone company is exactly what a tax examination looks for.

Flows that usually need documentation in a foreign-owned free zone manufacturer:

• Raw materials and components bought from the parent or group companies.
• Sales to group distributors abroad, or to a related company in Turkey (the taxable leg).
• Royalties, technical service fees and management fees charged by the parent.
• Intercompany loans, which also raise thin capitalisation questions under Corporate Tax Law Article 12.

Our transfer pricing and intercompany compliance guide covers methods and documentation in more depth.

Payroll and SGK in a free zone: what changes and what does not

Turkish labour and social security law applies inside free zones as it does elsewhere. The employer registers the workplace with the Social Security Institution (SGK), notifies each hire before work starts, reports terminations within ten days and files the monthly withholding and social security return by the 26th. Only the payroll income tax can be exempt.

• Workplace registration with SGK no later than the date the first employee starts (Law No. 5510, Article 11).
• Hire notices before the employee starts work (Article 8) and termination notices within ten days (Article 9).
• Minimum wage and overtime rules apply in the zone as elsewhere in Turkey.
• Time worked outside the zone tracked per employee, because those wages fall outside the exemption.
• Work permits for foreign staff follow the general rules; the free zone does not replace them.

For headcount planning, see our 2027 employer cost, tax and SGK guide and our payroll services for foreign companies.

Compliance calendar for a free zone company

The monthly rhythm is set by the withholding and social security return, due by the 26th of the following month, and by VAT returns, due by the 28th where the company has VAT obligations. The annual rhythm is set by the corporate tax return (30 April for a calendar year), the transfer pricing report due by the same date, sworn CPA certifications and the parent’s year-end and APR dates.

What happens if…

What happens if the 85% export test fails?

The payroll income tax deferred during the year becomes payable with late-payment interest (gecikme zammı), but no tax penalty is imposed. A quarterly ratio forecast shows the risk early: if exports abroad are tracking below 85%, you can budget for the tax, or check whether deliveries to zone exporters can be documented as export-registered deliveries.

What happens if part of the production is sold into Turkey?

The profit on those sales is taxable under the general corporate tax rules, the goods enter Turkey under import procedures, and, according to the Ministry of Trade, a production user pays a 0.9% Special Account fee on the FOB value. The sales also stay in the denominator of the 85% payroll test. If the buyer is related, the price falls inside the transfer pricing report.

What happens if the exemption exceeds TL 500,000 and no YMM report is filed?

General Communiqué No. 49 makes the sworn CPA certification report a condition for benefiting from the listed exemptions above the threshold. Without it, the exemption claimed in the return is exposed in a tax examination. A company with a full certification (tam tasdik) agreement can cover the exemption inside the full certification report.

What happens if the operating licence expires or is cancelled?

The exemptions are tied to licensed activity in the zone, so they stop with the licence. A company keeping foreign-currency books must return to Turkish lira from the start of the accounting period after its zone activity ends, as a recent Istanbul ruling confirmed. Plan the renewal, or the exit, well before the licence date.

What happens if the parent wants USD books halfway through the year?

The currency cannot be changed in the middle of an accounting period, because books are opened and closed by period under Tax Procedure Law Article 174. The change takes effect from the start of the next period, so the decision belongs in year-end planning.

Case analysis

The cases below are anonymised and simplified composites of situations seen in free zone files; names, figures and details are changed.

What drives the cost of accounting for a free zone company in Turkey?

The fee for a free zone company is driven by complexity more than turnover: transaction and transaction-form volume, headcount and payroll exemption tracking, the split of sales by destination, reporting currency and language, the parent’s calendar and framework, audits and sworn CPA certifications, and related-party flows. A company with no revenue yet still carries most of the fixed compliance.

We do not publish fees. Proposals are confirmed in writing after a paid scoping consultation, so the price reflects the scope above rather than a headline monthly figure. For the wider market picture, see what drives the cost of accounting services for foreign companies in Turkey.

Turkish free zone vs onshore Turkey vs UAE free zone

For an export manufacturer, a Turkish free zone offers corporate tax and payroll tax relief that onshore Turkey does not, at the cost of transaction-form, licence and certification work. A UAE free zone offers 0% corporate tax on qualifying income for a Qualifying Free Zone Person, with mandatory audited financial statements and substance conditions. The right choice depends on where you manufacture and sell.

Some groups use both: a UAE entity as a trading hub and a Turkish free zone company for production. In that case the pricing between the two becomes the main tax question in both countries.

How to brief an accountant: ten facts to send before asking for a fee

To get comparable proposals for a free zone company, send ten facts: zone and licence type, licence date, expected headcount, monthly invoice and transaction-form volumes, expected sales split by destination, related-party flows, the parent’s country and reporting calendar, reporting framework and currency, any audit or bank requirements, and the planned production start date.

1. Zone and licence type (production, trading, services; tenant or investor user).
2. Licence and incorporation dates, which also decide the minimum-tax holiday.
3. Headcount now and expected at months 6 and 12, and whether anyone works outside the zone.
4. Monthly volumes: purchase invoices, sales invoices, bank transactions, transaction forms.
5. Expected sales split: abroad, same zone, other zones, Turkey.
6. Related-party flows: materials, sales, royalties, fees, loans.
7. Parent’s country and reporting calendar, including year-end and close days.
8. Reporting framework and currency: IFRS, Ind AS, US GAAP; USD, EUR or TL books.
9. Audit and bank requirements: APR, lenders, group auditors.
10. Production start date, so the pre-revenue phase is scoped separately.

Our guide on how to choose an accountant in Turkey covers the selection questions that apply beyond free zones.

Conclusion

A free zone company accountant in Turkey runs three systems at once: Turkish statutory compliance, the free zone exemption mechanics, and the reporting the foreign parent and its bank depend on. The rules changed in 2025 and again in 2026, the payroll test no longer moves in step with the corporate tax exemption, and sworn CPA certification has become a standard part of the annual cycle. A proposal that names each of these blocks, and states which sit inside the monthly fee, is the best predictor that the first year will run without surprises.

Frequently asked questions

Primary sources

• Law No. 3218 on Free Zones, Provisional Article 3 — mevzuat.gov.tr
• Law No. 7577, Article 4 (amending Provisional Article 3(2)(a)) — Official Gazette No. 33227, 17 April 2026
• Law No. 7524, Article 24 (free zone exemption) and Article 36 (minimum corporate tax) — Official Gazette No. 32620, 2 August 2024
• Free Zones Law General Communiqué (Serial No. 1) — Official Gazette No. 27167, 12 March 2009
• Corporate Tax Law No. 5520, Articles 12, 13, 14, 32, 32/A and 32/C — mevzuat.gov.tr
• VAT Law No. 3065, Articles 11/1-a, 12, 17/4-ı and 41 — mevzuat.gov.tr
• VAT General Implementation Communiqué, sections II/A-4 and II/F-4.9 — gib.gov.tr
• VAT Circular No. 60, section 3.6.2 (services performed in free zones) — gib.gov.tr
• Revenue Administration ruling B.07.1.GİB.4.34.17.01-KDV.17-1542 (8 September 2011) on services in free zones — gib.gov.tr
• Tax Procedure Law No. 213, Article 174 — mevzuat.gov.tr
• Tax Procedure Law General Communiqué No. 348, section 4 (bookkeeping in free zones)
• General Communiqué No. 49 under Law No. 3568 (sworn CPA certification of exemptions) — Official Gazette No. 33123, 30 December 2025
• Decision No. 2007/12888 on Disguised Profit Distribution through Transfer Pricing, Article 19, and Transfer Pricing General Communiqué (Serial No. 1), section 7
• Social Security and General Health Insurance Law No. 5510, Articles 8, 9 and 11 — mevzuat.gov.tr
• Turkish Commercial Code No. 6102, Article 397 — mevzuat.gov.tr
• Ministry of Trade, Free Zones General Information Note (May 2026)
• Ministry of Trade, free zone announcements (11 May 2026 notice on Law No. 7577)
• Reserve Bank of India, Form APR under the Foreign Exchange Management (Overseas Investment) Regulations, 2022
• UAE Ministry of Finance, Ministerial Decision No. 82 of 2023 (audited financial statements)

This article is provided for general informational purposes and does not constitute legal, tax, accounting or investment advice. Turkish tax treatment depends on the company’s licence, activity, structure, contracts, documentation and specific facts, and the Indian requirements described depend on the parent’s position under Indian law. Professional advice should be obtained before taking action. Rules stated as of 13 November 2026.

Prefer SYSTEMS CPA in Google results: add SYSTEMS CPA as a preferred source.