TURKEY Trends and Developments Contributed by: Caghan Tansel, TANSEL
persons, suspicious transaction reporting, requests for information and documents, and compliance pro- gramme obligations. In practice, a CASP entering Tür- kiye should expect to build a bank-grade AML architec- ture rather than a light-touch crypto onboarding flow. The Travel Rule is particularly important. Türkiye’s FATF-aligned rules require CASPs to collect and transmit sender and recipient information for relevant crypto transfers, with enhanced attention to transfers above TRY15,000 and to transactions involving unreg- istered wallets or foreign institutions that do not share the required information. This tighter AML framework is also relevant to Türkiye’s international positioning. The FATF removed Türkiye from its increased-monitoring list in June 2024, and Türkiye remained outside the FATF’s grey list in later updates. For institutional investors, this reduces one historical concern; for CASPs, it means MASAK is likely to maintain close scrutiny to preserve that position. Tax: a Moving Target, but No Specific Crypto Transaction Tax Yet In 2026, a broader Turkish tax bill initially contemplated a crypto-asset transaction tax. The proposal referred to a tax on sales and transfers of crypto-assets at a rate of three per 10,000. However, those provisions were removed during the legislative process and did not become part of Law No 7577, which was pub- lished in April 2026. Accordingly, as of 18 May 2026, Türkiye has not enacted a standalone crypto-asset transaction tax. This does not mean that crypto activity is tax-free. General Turkish tax rules may still apply depending on: • the taxpayer’s legal status; • whether the activity is commercial or incidental; • the accounting treatment of the asset; • the nature of the income; and • whether the structure involves a Turkish entity, branch, platform, fund or individual investor. For international projects, the practical approach is to model at least three scenarios: • current law;
• a future low-basis-point transaction tax; and • ordinary income or corporate tax treatment for retained profits, service fees, staking-related rev- enue or treasury activities. Payments and the Digital Turkish Lira Türkiye’s payment restriction remains one of the most important limits on crypto use cases. Since April 2021, crypto-assets cannot be used directly or indirectly in payments under the Central Bank’s Regulation on the Disuse of Crypto Assets in Payments. The regulation also restricts payment institutions and electronic money institutions from mediating certain fund transfers to or from platforms that provide crypto-asset trading, custody, transfer or issuance services. This means that exchange, investment, custody and tokenisation models may be viable if properly licensed, but merchant checkout, crypto-to-fiat pay- ment intermediation and similar retail payment flows remain sensitive unless and until the Central Bank changes the rulebook. The Digital Turkish Lira should be analysed separately. The Central Bank continues to work on the second phase of the Digital Turkish Lira project, including pro- grammable payments, offline payments and interop- erability. The project is relevant for future settlement infrastructure, but it is a central bank digital currency initiative rather than a liberalisation of private crypto- assets for payments. For stablecoin, tokenised deposit and tokenised fiat projects, the safest design principle is coexistence rather than competition. Products should be struc- tured so they can adapt to future Central Bank stand- ards, but they should not assume that private tokens can be used freely for payment settlement under the current regime. ESG and Sustainability Reporting Sustainability reporting is becoming more relevant for larger digital-asset businesses, especially those operating energy-intensive infrastructure, custody technology, data centres, tokenisation platforms or carbon-credit-related products.
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