You are a Turkish affiliate marketing thMenu to local restaurants, but your commission arrives in USD from Synaltix LLC, headquartered in Albuquerque, New Mexico. To Turkish tax authorities, does that count as a "service export," and do you charge VAT on the invoice you issue?
VAT Law Article 11/1-a and 12/2: Service-Export Conditions
Turkish VAT Law (Law No. 3065), Article 11/1-a grants an export exemption, while Article 12/2 sets two service-export conditions: (i) the service must be rendered to a customer abroad, and (ii) the benefit of the service must be enjoyed abroad. In the affiliate model, your marketing/referral service is contractually delivered to Synaltix LLC in the U.S., and your commission is calculated as a share of Synaltix's global revenue.
An Izmir-based CPA firm issued a 2025 written opinion classifying thMenu affiliate commissions squarely as service exports at 0% VAT. The invoice must carry the legend "Service export — VAT Law Art. 11/1-a exemption," the payment must arrive in USD to a Turkish bank (with a Foreign Currency Purchase Slip / DAB), and you must retain contract/correspondence showing the service is consumed abroad.
"I Refer Turkish Restaurants — Doesn't That Break the Export Rule?"
This is the most confusing point. Even if your marketing targets restaurants located in Turkey, the invoice recipient is Synaltix LLC, not the restaurants. Picture a Turkish exporter selling goods to a Turkish retailer whose buyer-of-record is the parent company abroad — the sale qualifies as export. Here "customer" means the contractual counterparty, not the economic beneficiary.
The CPA opinion cites Turkish Ministry of Finance private rulings from 2018 and 2021: even when local consumers benefit from the service, if the service fee is paid by a foreign-resident entity under a contract with that foreign entity, the export-of-service test is met. As long as Stripe payouts arrive in Synaltix LLC's name, this criterion holds.
Practical Steps: Invoice, DAB, and VAT Refund
- Invoice: Issue via e-Arşiv in USD with the note "VAT Law 11/1-a Service Export Exemption." TRY equivalent is calculated at the CBRT effective sell rate on invoice date.
- DAB slip: Request a Foreign Currency Purchase Slip from your bank — a prerequisite for VAT refunds. Ask for it when Stripe transfers funds to Wise or your local bank.
- VAT refund: Input VAT (laptop, internet, ads) incurred to produce the export can be refunded. Monthly returns book the income under Line 11/1-a; the annual refund or offset claim is filed thereafter.
If you have not yet registered a sole proprietorship: incidental income below ~TRY 70,000/year (2026 threshold) only needs annual income-tax declaration. Above that, register a sole proprietorship — this triggers 4/B social-security and income tax, but VAT remains at 0%; you may not even need monthly VAT returns, only the annual income return.
FAQ
I have no business registration; can I still invoice? Below the incidental-income threshold, file an annual return only. Above it, register a sole proprietorship — 4/B and income tax kick in, but VAT stays at 0%.
Stripe pays me in TRY directly — still export? Yes. What matters is that the payer is a foreign-resident legal entity and the contract is with that entity. TRY settlement does not break the exemption, but you may need a SWIFT receipt instead of a DAB.
What if I am a restaurant owner using my own affiliate code? Self-referral is contractually prohibited (thMenu fraud policy) and fiscally risky — when the commission is not paid to an independent third party, the export classification can be challenged as a sham transaction.
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