A working reference for Turkish public-sector incentive programs for game studios.
PROGRAM
This is one of the support programs outlined in Decision No. 10962 dated February 26, 2026, regarding the definition and classification of Turkey’s service exports and the support of service sectors. Game studios qualify as bilişim sector beneficiaries (yararlanıcı). The legal definition of barındırma (Karar Article 3(b)) names dijital oyun explicitly, and the three flagship bilişim articles (hosting in Article 16, digital product promotion in Article 17, platform commission in Article 22) all name dijital oyun as in scope.
The Programme is administered by Ticaret Bakanlığı and disbursed through Hizmet İhracatçıları Birliği (HİB), the dedicated exporters' association for service sectors. Studios apply via DYS (Destek Yönetim Sistemi), the official application portal.
Base rate is 50% on eligible spend, with a +20-point uplift to 70% for activity targeted at countries the Ministry publishes on its target-country list (Karar Article 44). Each beneficiary is supported for up to five years per item unless the article states otherwise. All TL caps are revalued at the start of every calendar year using the rate published under VUK Article mükerrer 298(B). The same expense cannot be claimed under both HAP and the Markalaşma Programme; a studio elects one umbrella (Karar Articles 33(7), 45(4)).
Reimbursement of commissions paid to overseas agents that sell or distribute the studio's games (region-locked retail, key resellers, regional storefront partners).
Costs of certificates, accreditations and platform-specific compliance documents required for foreign markets. Examples: PEGI and ESRB rating fees, age-rating audits, ISO certifications, console-platform compliance documents.
Rent, brokerage commission, set-up certification and shared-office membership for offices the studio opens abroad. Useful for publishing, BD or co-development outposts.
General bucket for outbound advertising, promotional campaigns and marketing spend targeting foreign markets. Note: bilişim-sector studios should look at the more specific Dijital ürün tanıtım desteği below first, which carries a materially higher cap for game-specific marketing.
Costs of registering and defending domestically registered marks, patents and utility models abroad. Covers studio brand, game-title trademarks and patent filings outside Türkiye.
Individual or collective participation in trade shows, conferences and festivals abroad. Examples: Gamescom, GDC, Tokyo Game Show, PAX, Devcom. The cap doubles for events the Bakanlık classifies as prestigious.
Same logic as the overseas track but for internationally classified events held in Türkiye. Examples: Gaming Istanbul, regional game weeks of international standing. Prestige events get a 2x cap.
Server and cloud hosting for the studio's game, software or mobile app that delivers it to end users abroad. Examples: AWS, GCP, Azure, dedicated game-server hosts. "Dijital oyun" is named in the legal definition of barındırma (Karar Article 3(b)), so this is a clean fit for live-service titles.
The headline item for game studios under HAP. Covers advertising, promotion and marketing spend abroad for the studio's games. Karar Article 17 literally names "digital game". Under this provision, a beneficiary may receive support for up to 10 digital games per year.
Salary subsidy for international promotion and marketing personnel, both for staff based in Türkiye supporting overseas activity (yurt içi leg) and for staff posted to the studio's foreign unit (yurt dışı leg). Two parallel envelopes per beneficiary, 5 staff each, 5 years each.
Current Bakanlık practice has narrowed the eligible profile. The pre-2026 framework also supported developer and engineer positions; under the new framework the article scope is restricted to uluslararası tanıtım ve pazarlama personnel. Acceptable SGK titles in current practice include Business Development Specialist, Sales Consultant and Marketing Specialist. Adjacent functions such as community management, localisation management and live-ops marketing can fit when the employment contract iş tanımı and the SGK position are framed around the international promotion and marketing function; pure development, engineering or linguistics roles are out of scope. Same employee cannot be subsidised under another wage-cost programme (Karar Article 46).
The second standout item for games. Reimburses platform and storefront commission paid abroad on the studio's games. Examples: Steam, App Store, Google Play, Epic Games Store, PlayStation Store, Microsoft Store, Nintendo eShop. Under this provision, a beneficiary may receive support for up to 10 digital games per year.
Subscription to market reports and industry databases used to build overseas market-entry strategies. Examples: Newzoo, Sensor Tower, data.ai, Similarweb. Pre-approval is required for the report leg.
Membership dues for international industry bodies relevant to the studio. Examples: IGDA, ESA, European Games Developer Federation, regional game associations and standards bodies.
Purchase or rental of software licences. Karar Article 31 (Madde 31) gives a broad statutory scope, but the Bakanlık uygulaması in the 2026 framework has narrowed the eligible category set. Engine and DCC tooling that used to qualify under the pre-2026 framework (Unity, Unreal, Adobe, Maya, ZBrush, Substance, Houdini, Perforce) is currently treated as out of scope; the eligible list centres on sales, marketing, analytics, customer-data and CRM platforms. AI content generation tools (ChatGPT, Claude, Midjourney, Cursor) are not currently on the supported list. Category practice is still settling; high-value licence purchases should be checked against the active EK before commitment.
Eligible in current practice (examples):
Game analytics and product analytics (GameAnalytics, ThinkingData, Mixpanel, Amplitude, Heap, PostHog, Firebase Analytics); marketing analytics and attribution (Adjust, AppsFlyer, Sensor Tower); customer engagement and push (Braze, OneSignal, Customer.io, MoEngage, CleverTap); marketing automation (HubSpot, Mailchimp, Marketo); customer data platforms (Segment, RudderStack); CRM (Salesforce, HubSpot CRM, Pipedrive); sales intelligence (Apollo, ZoomInfo, Cognism, Clearbit).
Out of scope in current practice (examples):
Engine and development tooling (Unity, Unreal, Houdini, Maya, ZBrush, Substance); design (Figma, Canva, Adobe Creative Cloud); productivity and project management (Slack, Microsoft Teams, Jira, Asana, ClickUp, Linear, Notion, Confluence); AI content tools (ChatGPT, Claude, Midjourney, Cursor).
PROGRAM
The upper-tier brand-building track for service exporters with a domestically registered trademark and the operational maturity to scale abroad. Three nested tracks: Marka (4-year support window, ₺250M/year cap), TURQUALITY® (5 years per target market and per institutional/employment scope, ₺500M/year cap), and E-TURQUALITY® (this is specialized support for the information technology, software, and digital services sectors, which constitute the most strategic component of service exports). Since the program explicitly covers the sub-sectors of software, digital games, esports, financial technologies, blockchain, artificial intelligence, and smart cities, E-TURQUALITY is the appropriate program for most game studios to apply to.
Game studios enter as bilişim-sector beneficiaries. On top of the common toolkit (advertising, certification, units, consultancy, employment, registration, fairs), the bilişim set unlocks materially higher caps for digital-product promotion, platform commission, hosting, testing and value-added bilişim projects. See the cards below. Up to two domestically registered brands per beneficiary may be supported simultaneously. Once enrolled in the Markalaşma Programme, a studio cannot also draw on HAP for the same expense (Karar Article 33(7)).
Administered by Ticaret Bakanlığı and disbursed through Hizmet İhracatçıları Birliği (HİB) via DYS, with a yetkilendirilmiş yönetim danışmanlığı firması conducting the ön inceleme step before formal başvuru.
Same scope as HAP but bound to the brand's target-market plan. Falls under the beneficiary's annual umbrella cap (₺250M Marka, ₺500M TURQUALITY or E-TURQUALITY).
Same scope as HAP. Within the brand's coverage window; no separate TL cap (subject to the beneficiary's annual umbrella).
Rent, brokerage commission and shared-office membership for the brand's overseas units. Under Markalaşma the definition of "birim" additionally includes depo (warehouse) and antrepo (bonded warehouse). The +20-point target-country uplift applies.
Two combined envelopes that share a single TL ceiling: institutional infrastructure consultancy (organisation design, ERP and operations) and target-market consultancy (market entry, localisation, distribution). Pre-approval required.
Salary subsidy for international promotion and marketing personnel hired in Türkiye and for staff posted to the brand's foreign units. Single combined headcount cap of 10 people across both legs; 5-year window per beneficiary.
Current Bakanlık practice restricts eligible profiles to international promotion and marketing roles (Business Development Specialist, Sales Consultant, Marketing Specialist; adjacent functions such as community management and localisation management can fit when the iş tanımı and SGK position are framed around the international promotion and marketing function). Pure development or engineering roles are out of scope. Same employee cannot be subsidised under another wage-cost programme (Karar Article 46).
Same purpose as the HAP item. Under Markalaşma, reports follow the target-market timer (5 years per market) and database memberships sit on the institutional timer (5 years). Both within the annual umbrella.
Outbound advertising, promotion and marketing spend for the brand in foreign markets. Costs of the brand's corporate website also sit under this header but follow the duration of programme enrollment rather than the per-market timer.
One-off study mandated for brands entering the Markalaşma Programme. Includes current-state analysis, vision and sector benchmarking, gap analysis and a project roadmap for the support period. One per brand, ever.
Same scope as HAP but tied to the brand's target-market plan.
Same scope as HAP. 5-year window per beneficiary; no separate TL cap (subject to the umbrella).
Same scope as HAP. Runs while the brand remains in the programme; the +20-point target-country uplift applies.
Same scope as HAP for internationally classified events in Türkiye.
The flagship bilişim-sector item. Outbound marketing of the studio's games tied to the brand. Materially higher caps than HAP, and an even higher annual envelope under E-TURQUALITY®. Up to 20 games per year per beneficiary.
Same scope as HAP hosting but with a higher ceiling under Markalaşma.
Same scope as HAP (Steam, App Store, Google Play, Epic, console storefronts) but with substantially higher ceilings, and an E-TURQUALITY® uplift on top. Up to 20 games per year per beneficiary.
Foreign-procured testing and quality-assurance services for the studio's yazılım, mobil uygulama, dijital oyun or dijital aracılık platform. The Genelge E-TURQUALITY annex describes the scope as testler ve test çalışmalarında yurt dışında yerleşik kişilerden yararlanmak üzere yurt dışı şirket ve platformlar ile gerçekleştirilen çalışmalar.
In practice this covers QA services procured from foreign labs (functional QA, localisation QA, compatibility testing, certification preparation, security and penetration audits). Platform certification submission fees billed by the platform holder itself (Sony TRC, Microsoft XR, Nintendo lotcheck, App Store and Google Play technical review) are not the classical "test desteği" surface; acceptance varies and sits at the inceleme uzmanı's discretion when the invoice is structured as a service fee. There is no published whitelist of eligible providers, so high-value testing engagements should be confirmed against current EK practice before commitment. Pre-approval required.
Project-form support for engagements where the studio acts as the yüklenici delivering bilişim services to an overseas client. Karar definition: yararlanıcının yurt dışında yerleşik şirket, kurum ve kuruluş ile yüklenici ilişkisi içinde gerçekleştirdiği proje. The +20-point target-country uplift applies. Pre-approval required.
How this maps to game-studio engagements:
Work-for-hire development for an overseas publisher is the cleanest fit; the studio invoices as a contractor under a development or work-for-hire agreement. Co-publishing relationships are eligible only when the development phase is invoiced as a service for build (not pure revenue share); the contract must carve the service-fee component out explicitly. Tooling or middleware sold to an overseas studio does not fit this category; it is a product sale rather than a yüklenici project, and would be evaluated under the dijital ürün tanıtım, barındırma or platform komisyon articles depending on the model.
PROGRAM
Teknokent is the short name for Teknoloji Geliştirme Bölgeleri (Technology Development Zones), university-adjacent zones where R&D, design and software companies operate under a package of tax exemptions and cost subsidies established by Law No. 4691. The programme is administered by Sanayi ve Teknoloji Bakanlığı (Ministry of Industry and Technology). Game studios developing original titles inside a Teknokent zone qualify as software/R&D businesses and can access the full bundle of benefits below.
Admission requires applying to the relevant Teknokent management company (Yönetici Sirket) with an R&D, design or software project. The management company's evaluation board reviews the project and, if approved, issues a Proje Kabul Belgesi entitling the company to rent office space inside the zone and claim all statutory exemptions. Pre-company founders not yet registered as taxpayers can enter through the On Kulucka (pre-incubation) track instead, for up to 18 months.
All monetary exemptions are valid until 31 December 2028 unless otherwise noted. The main programme portal is teknopark.sanayi.gov.tr.
Profits generated exclusively from software, design or R&D activities carried out inside a Teknokent zone are fully exempt from corporate tax and income tax. Game studios qualify because game development is classified as yazilim (software) activity. The exemption window runs until 31 December 2028.
A studio operating inside a Teknokent can therefore earn game revenues (licensing, in-app purchases, export sales) tax-free on the income attributable to zone-based development work, provided revenues are tracked separately from any off-zone activities.
Income tax withheld on the salaries of R&D, design and qualifying support staff working in a Teknokent zone is cancelled (terkin edilir) rather than remitted to the tax authority. The waiver reduces the effective payroll cost for zone-based studios. The benefit runs until 31 December 2028.
Up to 20% of staff hours can be spent outside the zone and still qualify, with the President authorized to raise that ceiling to 100% for designated sectors or regions. Staff pursuing masters or doctoral degrees may also have up to 1.5 or 2 years of off-site time covered. Support staff are covered up to 10% of total R&D and design headcount (20% for companies with 15 or fewer staff).
Half of the employer-side social security premium owed on salaries that already benefit from the payroll income-tax waiver is covered by the Ministry of Finance budget. This effectively halves the employer's social security cost for qualifying Teknokent staff.
The benefit applies to the same off-site and postgraduate-study hours that qualify under the payroll income-tax waiver. The Teknokent management company is required to monitor compliance and notify the Social Security Provincial Directorate within 10 business days if a beneficiary no longer meets the conditions.
Software products developed and sold exclusively within a Teknokent zone are exempt from VAT. The exemption covers system management, data management, business applications, sectoral, internet, game, mobile and military command-and-control software. Digital games qualify explicitly under the 'game software' (oyun yazilimi) category.
To activate the exemption, the company must obtain approval from the Teknokent management company and apply to the relevant tax office. The benefit is available for as long as the company's earnings remain exempt from income and corporate tax (i.e. until 31 Dec 2028 under current rules).
New machinery and equipment purchased exclusively for use in R&D, innovation or design activities inside a Teknokent zone are exempt from VAT. This covers hardware used in game development such as workstations, motion-capture rigs, and server equipment. The exemption was extended by Presidential Decree No. 6583 and remains in force until 31 December 2024.
Note: check the current status of this exemption before relying on it, as the cited extension ran to end-2024 and a further renewal would require a new decree.
Equipment, materials and goods imported for use in Teknokent-based software, R&D, innovation or design projects are exempt from customs duty and all related levies. Documents and transactions related to such imports are also exempt from stamp tax and fees.
This benefit is particularly useful for studios importing specialist hardware (graphics processing units, development kits, haptic devices) or licensed technology required for their game development pipeline.
Employment contracts and related documents for R&D, design and qualifying support staff working in a Teknokent zone are exempt from stamp tax. Additionally, documents and transactions for R&D-related imports (see Customs Duty Exemption) are also exempt from stamp duty and fees.
The employment-related exemption runs until 31 December 2028.
Investors (individuals or companies) who contribute equity capital to a Teknokent-based company's eligible project can deduct that contribution from their taxable income. For individuals, the deduction is capped at 10% of declared income (after deductions and exemptions). For corporate investors, the cap is the lower of 10% of corporate profit or 20% of equity at the start of the fiscal year, with an absolute annual ceiling of TRY 1,000,000.
The incentive runs until 31 December 2028. The invested capital must remain in the company for at least four years; early withdrawal triggers back-payment of the deferred tax plus interest. This mechanism can make Teknokent startups more attractive to angel investors and corporate strategic partners.
Teknokent companies can employ foreign nationals as managers or as R&D/design staff (minimum bachelor's degree) under a streamlined process. The application to the Ministry of Labour goes through Sanayi ve Teknoloji Bakanligi's Ar-Ge Tesvikleri Genel Müdürlügü for a favourable opinion, reducing the friction that foreign hiring otherwise involves.
For international game studios setting up a Turkish R&D entity inside a Teknokent, or for domestic studios hiring senior foreign developers or artists, this facilitation meaningfully shortens the work-permit timeline.
Teknokent companies that hire doctoral-student R&D staff receive a monthly subsidy equal to the gross minimum wage per qualifying employee, paid for two years by the Ministry. The student must be enrolled in a Turkish university doctoral programme, have completed coursework, and be in the dissertation phase. The base salary paid by the company must be at least 1.5 times the gross minimum wage.
Each company can receive this support for up to two doctoral students at a time. The student must not be receiving equivalent public support from another institution. The benefit applies to hires made on or after 3 February 2021.
Teknokent staff can perform part of their zone-related work remotely and continue to benefit from all statutory exemptions and support as if they were physically in the zone. The default remote-work allowance is 20% of total hours or headcount, but the President is authorised to raise this ceiling sectorally or regionally, up to 100%.
For bilisim (IT) personnel whose profile is defined in the regulation (four-year computer/electronics/software graduates, and others working in software, design, analysis, networking or related testing and maintenance roles), the remote ceiling was set at 75% for 2022-2023 and at 100% for the April-December 2023 period by separate Presidential Decrees. Studios should verify the current applicable rate before structuring hybrid arrangements.
Teknokent companies whose annual tax-exempt profit exceeds TRY 1,000,000 must transfer 2% of that exempt amount into a dedicated reserve account. This amount must then be invested by year-end in Turkish venture capital investment funds, venture capital investment trusts, or as direct equity into other Teknokent incubatee companies.
Failure to make the transfer means 20% of the year's exempt earnings become ineligible for the tax exemption, with resulting back-taxes charged (without a tax-loss penalty). The annual obligation is capped at TRY 20,000,000. The President can adjust the rate and caps by up to five times or down to zero. This mechanism channels successful Teknokent companies' profits back into the startup ecosystem.
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