Turkey has established one of the most extensive double taxation agreement (DTA) networks in the region, with over 85 bilateral treaties in force. These agreements play a critical role in protecting foreign investors from being taxed twice on the same income, making Turkey an increasingly attractive destination for international business. This guide covers everything you need to know about Turkey’s DTA network as of 2026.
What Are Double Taxation Agreements?
A Double Taxation Agreement (also known as a Double Tax Treaty or DTA) is a bilateral agreement between two countries that determines which country has the right to tax specific types of income. These agreements prevent the same income from being taxed in both countries, eliminating a major barrier to international trade and investment.
DTAs typically cover corporate income tax, personal income tax, dividends, interest, royalties, capital gains, and income from professional services. They establish clear rules for determining tax residency and allocating taxing rights between the contracting states.
Turkey’s DTA Network — Key Treaty Partners
Turkey has active DTAs with over 85 countries spanning Europe, Asia, the Americas, Africa, and the Middle East. Key treaty partners include:
Europe
United Kingdom, Germany, France, Italy, Spain, Netherlands, Belgium, Austria, Switzerland, Sweden, Norway, Denmark, Finland, Poland, Czech Republic, Hungary, Romania, Bulgaria, Greece, Ireland, Portugal, Luxembourg
Americas
United States, Canada, Brazil, Mexico
Asia & Middle East
China, Japan, South Korea, Singapore, India, Pakistan, Malaysia, Indonesia, Thailand, Saudi Arabia, UAE, Kuwait, Qatar, Bahrain, Oman, Israel, Iran
Africa & CIS
Russia, Kazakhstan, Azerbaijan, Georgia, Ukraine, Uzbekistan, Turkmenistan, Egypt, South Africa, Tunisia, Algeria, Morocco, Ethiopia, Sudan
Reduced Withholding Tax Rates Under DTAs
One of the most significant benefits of DTAs is the reduction of withholding tax rates. Turkey’s standard withholding tax rates (without a treaty) are:
- Dividends: 10%
- Interest: 0%–10% (depending on type)
- Royalties: 20%
Under DTAs, these rates can be significantly reduced. Here are some common treaty rates:
| Country | Dividends | Interest | Royalties |
|---|---|---|---|
| United States | 5%–15% | 10%–15% | 5%–10% |
| United Kingdom | 5%–15% | 10%–15% | 10% |
| Germany | 5%–15% | 10%–15% | 10% |
| Netherlands | 5%–15% | 10%–15% | 10% |
| China | 10% | 10% | 10% |
| Russia | 10% | 10% | 10% |
| UAE | 10%–12% | 10% | 10% |
| Saudi Arabia | 5%–10% | 10% | 10%–12% |
How to Benefit from DTAs
To claim reduced withholding tax rates under a DTA, the following steps are typically required:
- Tax Residency Certificate: Obtain a certificate of tax residency from your home country’s tax authority proving you are a tax resident
- Apostille/Notarization: Have the certificate apostilled or notarized depending on the country
- Turkish Translation: Provide a Turkish translation of the certificate
- Submit to Revenue Administration: File the certificate with the Turkish Revenue Administration before the withholding tax is applied
It is important to submit the tax residency certificate before the income payment is made. If the certificate is not provided in time, the standard withholding rate will apply, and the overpayment must be recovered through a refund process.
Permanent Establishment (PE) Rules
DTAs define what constitutes a “Permanent Establishment” in Turkey. Under most of Turkey’s treaties (based on the OECD Model), a PE is defined as a fixed place of business through which the enterprise carries on its business. This typically includes offices, branches, factories, workshops, and construction sites lasting more than 12 months. If a foreign company is deemed to have a PE in Turkey, it becomes subject to Turkish corporate tax on the profits attributable to that PE.
Global Minimum Tax Impact (Pillar Two – 2026)
Starting in 2026, Turkey applies the OECD Pillar Two rules through a Qualified Domestic Minimum Top-Up Tax (QDMTT). Multinational enterprise groups with annual consolidated revenues exceeding €750 million face an effective minimum tax rate of 15% faces a minimum tax rate. This means that even if Turkish tax incentives reduce the effective tax below 15%, a top-up tax applies. These calculations are based on IFRS/UFRS standards rather than the Turkish Tax Procedure Law (VUK).
Celikel CPA — Your Partner in International Tax Planning
At Celikel CPA, we help international businesses structure their Turkish operations to maximize DTA benefits. Our services include withholding tax optimization, tax residency certificate management, transfer pricing documentation, PE risk assessment, and advisory on the new Global Minimum Tax rules.
Need expert guidance on double taxation? Contact us: yigit@celikelcpa.com | WhatsApp: +90 544 649 40 87
