Double Taxation Agreements in Turkey 2026: Complete Guide for International Businesses

Turkey has established one of the most extensive double taxation agreement (DTA) networks in the region, with more than 90 bilateral treaties in force. These agreements protect foreign investors from being taxed twice on the same income, which directly affects the after-tax return on Turkish operations. This guide explains how Turkey’s DTA network works as of 2026 and how to apply it to dividends, interest, royalties and service income.

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. For broader context on Turkish corporate rates, see our corporate tax in Turkey 2026 guide.

Turkey’s DTA Network - Key Treaty Partners

Turkey has active DTAs with more than 90 countries spanning Europe, Asia, the Americas, Africa, and the Middle East; the Revenue Administration’s list of agreements in force numbered 93 as of 23 April 2025. That list is dated, so it can lag behind new treaties: the agreement with the Hong Kong Special Administrative Region, for example, entered into force on 30 January 2026 according to Hong Kong’s Inland Revenue Department and applies on the Hong Kong side to years of assessment beginning on or after 1 April 2027. Check the Revenue Administration’s site for newer additions and for the date from which Turkey applies a new agreement. 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 on payments to non-resident companies (without a treaty) include:

• Dividends: 15% general domestic rate for qualifying payments from 22 December 2024

• Interest: depends on the type of payment; for corporate recipients the rates in the Revenue Administration’s withholding table are mostly between 0% and 10%

• Royalties: 20%

Under a DTA, a domestic rate may be reduced when the recipient is a treaty resident, is the beneficial owner where required, and meets any ownership and procedural conditions. Each treaty sets its own maximum rates that Turkey may withhold as the source state on dividends, interest and royalties. Many treaties give a lower dividend rate only above a minimum shareholding, and a lower interest rate only for certain lenders or loans, and the thresholds and protocol amendments differ for every partner country. For that reason this guide does not reproduce a rate table.

For a specific payment, check the Revenue Administration’s tables of treaty rates for dividends and for interest and royalties, then read the treaty article and any protocol against current domestic law. The list of treaties in force and the treaty texts are published on the Revenue Administration’s website (see the list of agreements). Where the domestic rate is already lower than the treaty rate, such as the 15% domestic dividend rate, the lower domestic rate generally applies.

How to Benefit from DTAs

To claim reduced withholding tax rates under a DTA, the Revenue Administration’s residence certificate circular (ÇVÖA/2013-1) calls for the following:

• Residence certificate: an original certificate from the competent tax authority of your home country showing that you are a tax resident there

• Certified Turkish translation: a Turkish translation of the certificate certified by a notary or by a Turkish consulate; the circular does not mention an apostille

• Present it to the payer: give the original and the translation to the Turkish payer that withholds the tax (the withholding agent), who keeps them to present to the competent authorities when needed; where no tax is withheld, present them to the tax office

As a practical step, give the certificate to the payer before the income payment is made, because the payer needs it when it decides whether to withhold. The circular itself sets no deadline for this. It says that if no certificate is presented, Turkish domestic law applies instead of the treaty provisions, so the standard withholding rate is applied and any later reclaim is a separate procedure.

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 or installation projects that exceed the duration set in the specific treaty (see permanent establishment rules in Turkey). If a foreign company is deemed to have a PE in Turkey, it becomes subject to corporate tax in Turkey on the profits attributable to that PE.

Global Minimum Tax Impact (Pillar Two - 2026)

Turkey introduced global and domestic minimum top-up tax rules, aligned with the OECD Pillar Two framework, in Law No. 7524 of July 2024 as a new part of the Corporate Tax Law. In-scope multinational groups are those whose consolidated revenue exceeds EUR 750 million in at least two of the four preceding years, and the minimum rate is 15%. The effect of treaty relief and Turkish incentives must be modelled under the detailed group- and jurisdiction-level calculation; it is not a simple replacement for treaty rules.

Apply the Treaty to the Operating Facts

A treaty rate is only part of the analysis. Foreign enterprises should first map permanent establishment risk in Turkey and then test registration, withholding and profit-attribution consequences against the relevant treaty.