International Digital Export Structuring

Structure for Margin.
Comply for Durability.

LaunchEntities designs compliant cross-border operating architectures that reduce your effective acquisition cost and optimize global revenue flows through Türkiye's Digital Export and E-Export Incentive Framework.

Indicative Operating Architecture
Founder / Existing EntityEU or International Home Jurisdiction
Optimized LayerTurkish Digital Export Operating Entity (Ltd. / A.Ş.)
Incentive RecoveryAdvertising, Platform Commission, IP, HR, Market Entry Support
Capital FlowCompliant Repatriation via Dividend / IP Royalty

Illustrative only. All structures subject to individual jurisdiction analysis, substance review, and full compliance assessment prior to implementation.

Institutional Context

Operating Within the Official Framework

LaunchEntities maintains advisory relationships with industry bodies operating within Türkiye's export association network, including entities aligned with the Hizmet İhracatçıları Birliği (HIB) ecosystem. Our structuring methodology operates within the official e-export incentive framework administered by the Ministry of Trade and its designated sectoral associations. We do not claim official partnership status with any Ministry or governmental body.

We maintain active communication channels with Ministry-integrated industry bodies to monitor program updates, pre-approval requirement revisions, and regulatory guidance as it is issued. This operational coordination is how we ensure that structures we design remain current with the program's evolving requirements — not a function of any formal institutional endorsement.

Our structuring philosophy is compliance-first in all phases: eligibility assessment, entity design, IP structuring, and ongoing claim operations. Every architecture we propose is reviewed against the program's formal eligibility criteria and the applicable cross-border tax standards before any implementation proceeds. All incentive approvals remain subject to the formal review process of the relevant authority. Eligibility determinations depend on individual company profile, documentation quality, and compliance with current program requirements — no outcome is guaranteed by structural design alone.

This section is provided for institutional context only. LaunchEntities does not claim official partnership with any government ministry or guarantee regulatory outcomes. All structuring decisions require independent qualified professional counsel in all relevant jurisdictions.

Program Prerequisites

Every structure we build must satisfy Türkiye's formal eligibility framework. These are non-negotiable prerequisites — we verify them before any implementation proceeds.

01

Turkish Entity

Ltd. Şirketi or A.Ş. must be established in Türkiye as the operating entity.

02

NACE Compliance

Main business activity must fall within the qualifying IT sub-sector under NACE classification.

03

İHKİB Membership

Membership in the Service Exporters' Association. Requires active e-signature and KEP (registered email) credentials.

04

Invoice and Payment Discipline

All supported expenses must be invoiced to and paid from the Turkish entity. Deviations disqualify claims.

05

International Targeting

All supported spend must have demonstrable foreign market orientation. Domestic-targeted spend is ineligible.

The Structural Problem

Digital unit economics are under sustained, structural pressure.

Rising Customer Acquisition Costs

CPM inflation across major paid channels has structurally compressed unit economics. Most EU-based digital companies absorb this cost in full, with no structural mitigation at the entity level.

Platform Commission Drag

App store and marketplace commissions of 15–30% are embedded in every revenue cycle. For mobile-first companies, this is often the largest cost line below gross margin — and one that can be partially addressed through compliant platform commission support.

EU Tax Exposure Without Structural Mitigation

Founders operating through a single domestic entity carry full statutory rate exposure with no access to export incentive frameworks available in other jurisdictions.

Unoptimized Cross-Border Structure

Most founder-led companies retain their founding jurisdiction indefinitely. As international revenue scales, this creates CFC risk, PE risk, and foregone incentive eligibility — none of which become visible until it is too late to act efficiently.

IP in the Wrong Jurisdiction

Intellectual property sitting in high-tax jurisdictions generates maximum royalty exposure and forfeits access to IP incentive regimes available elsewhere. IP location decisions made at founding compound materially at scale.

30%

Platform commission embedded in every app store revenue cycle — a structural cost partially addressable through compliant incentive support.

0

Incentive recovery for founders who have not structured for digital export eligibility, regardless of international revenue scale.

60%

Reimbursement rate available across qualifying spend categories — for companies that have structured correctly and maintained documentation discipline.

Figures for contextual illustration. Individual outcomes depend on structure, compliance, and claim eligibility. No outcome is guaranteed.

Our Methodology

A Compliant Architecture, Not a Paperwork Exercise

We do not file applications. We design end-to-end compliant operating structures — legal entities, IP frameworks, revenue routing, transfer pricing, and documentation systems — where incentive eligibility is the structural output, not the starting point.

Every engagement begins with a full eligibility and jurisdiction analysis. Every structure we build must withstand examination by Türkiye's export support authority, the founder's home jurisdiction tax authority, and international transfer pricing standards.

01

Turkish Digital Export Entity

Ltd. or A.Ş. formation with correct NACE classification, genuine substance, and İHKİB membership pathway.

02

IP Transfer or Licensing Architecture

Transfer pricing-aligned IP structures with arm's-length royalty logic, DEMPE analysis, and documentation plan.

03

Revenue and Invoice Routing

Marketplace migration planning, billing entity alignment, and invoice flow design to preserve claim eligibility.

04

Pre-Approval and Spend Governance

Calendar management for categories requiring pre-approval. Spend without pre-approval is irrecoverably ineligible.

05

Cross-Border Tax Risk Management

PE risk screening, CFC analysis, treaty eligibility review, and substance documentation in founder home jurisdiction.

06

Audit File and Documentation System

Folder structure, evidence collection SOPs, and claim file standards that survive audits and reimbursement reviews.

Economic Impact Modeling

How Incentive Recovery Reduces Effective Acquisition Cost

The economic logic is straightforward: qualifying paid acquisition spend directed at international markets may be eligible for 60% reimbursement under the advertising and promotion support category — for up to three primary digital products, with separate caps for additional products.

Platform commissions paid to Apple, Google, or equivalent international distribution platforms may qualify for 50% reimbursement under the platform commission support category, subject to invoicing and payment discipline from the Turkish entity.

For a company spending €60,000 monthly on paid acquisition and €15,000 in platform commissions — both fully structured for eligibility — the combined incentive recovery across a 5-year support period can represent material margin recapture at the cohort level.

We do not model outcomes we cannot substantiate. All economic scenarios are presented as probabilistic ranges, never as guarantees. Actual recovery depends on structure, claim eligibility, documentation, and ongoing compliance.

Illustrative Monthly Scenario

Paid Acquisition Spend (Int'l-targeted)€60,000
Platform Commission (Apple/Google)€15,000
Advertising Support Rate (up to)60%
Platform Commission Support Rate50%
Indicative Monthly RecoverySubject to Caps
Effective CAC ReductionMaterial — Structure-Dependent

This scenario is illustrative only. Annual caps apply per product and category. No recovery amount is guaranteed. Actual outcomes depend on structure, NACE compliance, invoicing discipline, pre-approval adherence, and product mapping. All figures subject to individual assessment.

Who This Is For

This structure works for specific companies. We are explicit about fit.

This engagement is designed for

  • SaaS and mobile app companies with international customers and meaningful paid acquisition budgets
  • Founders generating €20,000–€200,000+ MRR with majority revenue from outside their home country
  • Companies distributing through Apple App Store, Google Play, or direct international channels
  • Founders willing to establish genuine operational substance in Türkiye and maintain documentation discipline
  • Companies seeking long-term compliant architecture — not short-term arbitrage

This engagement is not for

  • Domestic-only businesses with no international revenue or market targeting
  • Operators seeking guaranteed approvals or short-term financial engineering
  • Founders unwilling to establish real Turkish entity substance or maintain audit-file documentation
  • Companies where NACE activity alignment is not achievable without misrepresentation
  • Operators with unresolved non-compliance in existing tax obligations
How We Work

Five phases from assessment to ongoing operations

01

Assessment Call

Eligibility review, product fit, jurisdiction analysis, honest view of structural feasibility and expected economics.

02

Blueprint Delivery

Full Strategic Structuring Blueprint: entity design, IP model, tax risk screen, grant category roadmap, economic model.

03

Implementation Sprint

Entity formation, banking coordination, IP documentation, marketplace migration, invoicing system, pre-approval workflow.

04

Reimbursement Operations

First claim cycle preparation, ongoing submission coordination, pre-approval calendar management, documentation audits.

05

Governance and Optimization

Substance playbook, board governance, margin modeling, product portfolio strategy, exit-readiness alignment.

Service Architecture

Three Tiers of Engagement

We do not offer standalone application filing. Every engagement is structured as a complete advisory relationship.

Tier One

Strategic Blueprint

Assessment and architecture design
  • Eligibility and product mapping assessment
  • Entity and NACE activity design
  • IP model recommendation
  • PE and CFC risk screening
  • Transfer pricing outline
  • Grant category roadmap with pre-approval flags
  • Economic model (scenario-based, no guarantees)
  • Implementation plan and responsibility matrix
Tier Two

Implementation & Legal Architecture

End-to-end structure execution
  • Turkish company formation coordination
  • İHKİB membership pathway (e-signature + KEP)
  • Banking compliance preparation package
  • IP transfer or license agreement package
  • Marketplace migration plan
  • Invoicing and payment flow setup
  • Audit file documentation system
  • First reimbursement cycle preparation
Tier Three

Optimization & Ongoing Advisory

Operations, governance, exit readiness
  • Ongoing claim operations and submission
  • Pre-approval calendar and spend governance
  • Product portfolio optimization (Top 3 strategy)
  • Margin optimization and reinvestment modeling
  • Governance and substance playbook
  • Exit readiness: IP chain-of-title, intercompany alignment
Cross-Border Tax and Legal Layer

The differentiator: structuring that survives international tax scrutiny

IP Transfer vs. Licensing Model

Each model carries distinct implications for exit tax, ongoing flexibility, valuation, and transfer pricing. The correct choice depends on your current IP jurisdiction, the maturity of the asset, and your exit timeline.

Transfer Pricing Compliance

Royalties or IP transfer values must be arm's-length and documented under DEMPE logic. Without contemporaneous documentation, intercompany arrangements are vulnerable to adjustment by any relevant tax authority.

Permanent Establishment Risk

If effective management and key commercial decisions remain in the founder's home country, the Turkish entity may be treated as a PE — exposing Turkish profits to home-country taxation. Substance planning is not optional.

Controlled Foreign Corporation (CFC) Risk

Many EU jurisdictions apply CFC rules that can attribute Turkish entity profits to the founder-shareholder in their home country. The extent of exposure depends on jurisdiction, ownership percentage, and income type.

Treaty Eligibility and Withholding

Dividend and royalty withholding rates depend on treaty availability, beneficial ownership, and demonstrable substance. Structures lacking genuine management presence may not qualify for treaty protection.

Structuring for Margin, Valuation, and Exit

The downstream benefit of a correctly structured Turkish digital export entity is not merely incentive recovery. A clean, well-governed entity with documented IP ownership, arm's-length intercompany agreements, and transparent revenue flows is structurally superior for capital events.

Margin optimization through incentive recovery expands EBITDA. A higher-margin business with a clean IP chain-of-title commands a superior valuation multiple. Exit readiness is a consequence of structural discipline — not a separate exercise undertaken before a transaction.

We frame this explicitly because it determines how we scope every engagement: not as a reimbursement exercise, but as a permanent improvement to the financial architecture of your business.

The information on this website does not constitute tax or legal advice. All structuring decisions require qualified professional counsel in all relevant jurisdictions.

Common Failure Points

Why most attempts at this structure fail

These are the documented failure modes that result in claim rejection, clawback, or regulatory exposure. Understanding them is prerequisite to designing a structure that avoids them.

  • Spending on qualifying categories before obtaining required pre-approval. Pre-approval is mandatory for certain categories and cannot be retroactively obtained.
  • Campaigns or spend with domestic targeting — or insufficient documentation of international market orientation.
  • Invoices not in the Turkish entity name, or payments made from non-Turkish bank accounts.
  • NACE code mismatch between registered activity and actual business operations.
  • Insufficient documentation of IP ownership or product rights — particularly where IP has been informally developed or is held by an individual rather than the entity.
  • Missing audit-file documentation: screenshots, contracts, invoices, payment proofs, and campaign targeting evidence.
  • Incorrect product classification — misapplying Top 3 product caps to products that should be categorized separately.
  • Misclassifying software updates as new development for employment support eligibility.

Our Compliance Commitment

We do not design structures that lack genuine commercial substance. Every entity we establish must operate as a real business, with real management, real operations, and real decision-making in Türkiye.

We do not offer tax evasion schemes. Our structures are designed to withstand examination by export support authorities, home-jurisdiction tax authorities, and OECD BEPS-standard transfer pricing review.

We do not guarantee incentive approvals or specific recovery amounts. We build structures that are auditable, documentable, and defensible — and we equip our clients to maintain them.

We require clients to maintain ongoing documentation discipline. A structure that cannot survive an audit is not a compliant structure — it is an exposure.

This website is for informational purposes only. Nothing here constitutes tax, legal, or financial advice. Independent professional advice is required before any structuring decisions.

Insights

Analysis for founders navigating international digital structures

Structuring

IP Transfer vs. Exclusive License: A Framework for Digital Export Architecture Decisions

The choice between transferring IP to a Turkish entity or licensing it determines exit tax exposure, ongoing flexibility, and transfer pricing complexity. This analysis covers the trade-offs by scenario.

Tax Risk

CFC Rules and Turkish Entities: What EU-Resident Founders Need to Understand Before Structuring

German, Dutch, French, and UK CFC regimes each apply differently to Turkish-entity structures. Understanding the passive income and threshold rules is prerequisite to structuring safely.

Program Operations

Pre-Approval in the E-Export Framework: Categories, Timelines, and the Consequences of Getting It Wrong

Certain spend categories require pre-approval before any expenditure. This piece maps which categories, what the approval process involves, and how to manage the calendar.

Transfer Pricing

Arm's-Length Royalty Rates for Mobile App IP: Benchmarking Approaches and Documentation Standards

Setting a defensible royalty rate between a founder's home-country holding entity and a Turkish operating entity requires a documented comparable analysis. This covers methodology and common errors.

Documentation

The Audit File: What Documentation the Export Support Authority Expects and How to Build a Claim-Ready System

Claim rejection is most commonly a documentation failure, not a structural one. This piece describes the evidence standards, folder organization, and collection cadence that underpin a defensible claim file.

Valuation

From Incentive Recovery to Valuation Multiple: How Structural Margin Improvement Compounds in a Digital Exit

The economic case for structuring is not limited to reimbursement. This analysis models how margin recapture through incentive recovery translates into EBITDA expansion and multiple-of-revenue valuation uplift.

Whitepaper

The Digital Export Structuring Guide for SaaS and App Founders

A structured briefing document covering Türkiye's Digital Export Incentive Framework, the cross-border tax considerations relevant to EU and international founders, common structuring errors, and a self-assessment checklist for eligibility evaluation.

Approximately 24 pages. No sales content. Written for founder and CFO-level readers.

Download the Whitepaper

Delivered by email. No obligation.

No obligation. We do not share your data with third parties. Not legal or tax advice.

Services

Three Tiers. One Architecture.

We do not file paperwork. We design and implement compliant international operating structures — then operate them alongside you. Each tier builds directly on the last.

Tier One

Strategic Structuring Blueprint

Confirm eligibility, design the compliant architecture, and quantify the economic impact — before any implementation spend is committed.

Eligibility and Product Mapping Assessment

Full review of your current products, revenue composition, international market orientation, and NACE activity fit. Honest assessment of whether the structure is viable before any commitment.

Entity and NACE Activity Design

Recommended entity type (Ltd. or A.Ş.), activity code alignment, and registered activity description to satisfy program eligibility requirements without misrepresentation.

IP Model Recommendation

Analysis of IP transfer vs. exclusive license models with specific trade-offs for your situation: exit tax exposure, flexibility, transfer pricing complexity, and treaty access.

PE and CFC Risk Screening (High-Level)

Initial assessment of permanent establishment exposure in the founder home jurisdiction and CFC risk based on applicable domestic rules — with referral to qualified local counsel for full analysis.

Transfer Pricing Outline

Royalty rate logic framework and documentation plan outline, including DEMPE analysis approach and comparable benchmarking strategy.

Grant Category Roadmap

Mapping of qualifying spend categories against your business profile, with explicit identification of categories requiring pre-approval and recommended claim timeline.

Economic Model

Scenario-based model of effective CAC and gross margin impact under compliant structure. Presented as probabilistic ranges with explicit assumptions. No guaranteed figures.

Implementation Plan

Phased implementation checklist with task ownership, sequencing, dependencies, and responsible party matrix for founder, counsel, accountant, and LaunchEntities.

Tier Two Tier Three

Optimization, Reimbursement Operations & Valuation Advisory

Ongoing system, claims discipline, and the structural path from margin improvement to exit readiness.

Ongoing Claim Operations

Continuous reimbursement cycle management including documentation collection, claim file preparation, submission coordination, and response management for authority queries.

Pre-Approval Calendar and Spend Governance

Forward-looking calendar management for all pre-approval-dependent categories. Spend governance framework to prevent ineligible expenditure in real time.

Product Portfolio Optimization

Strategic management of Top 3 product classification to maximize incentive recovery across the product portfolio while maintaining compliance with per-product cap structures.

Margin Optimization Modeling

Ongoing modeling of incentive recovery against acquisition spend, with CAC-to-recovery ratios and reinvestment strategy recommendations.

Governance and Substance Playbook

Board meeting protocol, decision documentation, contract management system, and substance evidence file to support PE risk mitigation and treaty benefit eligibility.

Exit Readiness Alignment

IP chain-of-title documentation, clean intercompany agreement register, investor-friendly entity structure review, and pre-transaction diligence preparation guidance.

Engagement Principles

What defines every engagement we accept

01

Compliance-First

We do not offer tax evasion or workaround schemes. Every structure must withstand examination by all relevant authorities.

02

No Approval Guarantees

We build structures that survive audits. We do not promise outcomes that depend on authority discretion.

03

Substance Required

Clients must maintain genuine operational substance and documentation discipline. Structures without substance are exposures, not structures.

04

Fit Over Volume

We work best with companies that have real international revenue, meaningful paid acquisition, and founders committed to long-term structural discipline.

Run an eligibility review before committing.

We review each assessment individually. Submissions are only progressed where there is a credible basis for compliant structuring value.

No obligation. We respond within 48 business hours. Not legal or tax advice.

The Program

Türkiye's Digital Export Incentive Framework

A structured overview of the program architecture, eligibility prerequisites, qualifying support categories, and the documented failure points that most structures do not survive.

Program Architecture

Türkiye's Digital Export and E-Export Incentive Framework provides reimbursement support for qualifying international-market expenditure by Turkish-registered IT and digital services companies. The framework operates within the official export support architecture administered by the Ministry of Trade in coordination with the Service Exporters' Association (İHKİB) and related sectoral associations. LaunchEntities maintains advisory relationships with industry bodies operating within this framework and monitors regulatory updates through active coordination channels.

The support period is five years per qualifying company. Most categories operate on a 60% reimbursement basis with product-based annual caps. Platform commission support operates at 50%. Pre-approval is required for certain categories before spend is incurred. All approvals remain subject to the formal review process of the relevant authority.

Core Category

Advertising, Promotion and Marketing

Digital advertising spend for software, mobile apps, and digital products directed at foreign markets. Includes app store advertising, paid social, search, and programmatic campaigns.

Up to 60% reimbursement · Product-based annual caps · Top 3 products differentiated

Core Category

Platform Commission Support

Commissions paid to international distribution platforms (Apple App Store, Google Play, and equivalents) in connection with international sales of qualifying digital products.

Up to 50% reimbursement · Annual cap applies

Core Category

Market Entry Support

Localization, translation, digital file preparation, and international hosting costs associated with entering foreign markets. Hosting costs subject to separate annual cap.

Up to 60% reimbursement · Hosting cap separate

Supporting Category

IP Registration and Protection

Costs associated with trademark registration, patent application, and intellectual property protection in foreign jurisdictions. Requires documentation of IP ownership by the Turkish entity.

Up to 60% reimbursement

Supporting Category

Reports and Data Analysis

Market research, competitive intelligence databases, industry reports, and data subscriptions directly related to international market development.

Up to 60% reimbursement

Supporting Category

Certifications

International standards certifications, security certifications, and compliance certifications required for access to foreign markets or distribution platforms.

Up to 60% reimbursement

Supporting Category

Employment Support

Support for employment costs related to new software development activity — explicitly not maintenance or updates. Requires qualification of the specific role and activity.

Up to 60% · New development only

Supporting Category

Software License and Hardware

Software licenses and hardware rental costs directly related to qualifying international market activity. Subject to documentation of business purpose.

Up to 60% reimbursement

Supporting Category

Overseas Unit and Agency Support

Costs associated with establishing or operating overseas representative offices or engaging international distribution agents for digital product sales.

Up to 60% reimbursement · Pre-approval may be required

Eligibility Prerequisites

Non-negotiable requirements before any application can proceed

#
Requirement
Implementation Implications
1
Turkish Entity (Ltd. or A.Ş.)
The company receiving support must be registered in Türkiye as a Limited Şirketi or Anonim Şirketi. Foreign branches or representative offices do not qualify. Entity formation typically takes 2–4 weeks with qualified local counsel.
2
NACE Activity Compliance
The company's registered primary activity must fall within the qualifying IT sub-sector under the Turkish NACE classification system. Mismatch between registered activity and actual operations is a documented rejection cause.
3
İHKİB Membership
Active membership in the Hizmet İhracatçıları Birliği (Service Exporters' Association) is required. Membership requires an active e-signature credential and KEP (Kayıtlı Elektronik Posta — registered electronic mail) account. Both must be established before membership can be processed.
4
Invoice and Payment Discipline
All supported expenditure must be invoiced to the Turkish entity — not to the founder personally or any non-Turkish entity — and paid from a Turkish entity bank account. Any deviation disqualifies the specific invoice from reimbursement. This applies retroactively; there is no correction mechanism.
5
International Market Orientation
All supported spend must be demonstrably directed at foreign markets. Campaigns with domestic Turkish targeting components require clear segmentation and documentation of the international portion. Domestic spend is categorically ineligible and its inclusion can jeopardize the entire claim.
Common Rejection Causes

Why structurally valid claims fail in practice

Spending Without Pre-Approval

Certain categories require authority pre-approval before any qualifying spend is incurred. Spending without pre-approval renders the entire claim for that category ineligible. This is not correctable retroactively.

Domestic Targeting

Advertising spend directed at Turkish domestic audiences, or campaigns that cannot demonstrate international market targeting through geo-targeting documentation, is categorically ineligible.

Invoice or Payment Failure

Any invoice not addressed to the Turkish entity, or payment made from a personal or non-Turkish account, disqualifies that specific expense from reimbursement. No correction mechanism exists.

NACE Mismatch

Where the registered NACE activity does not match actual business operations, the entire company may be found ineligible. This requires proactive structuring at entity formation stage.

Weak IP Documentation

Claims for products where IP ownership cannot be clearly documented to the Turkish entity are vulnerable to rejection. Informally developed IP or IP held by an individual founder is a common failure point.

Incomplete Audit File

Missing screenshots, incomplete contracts, absent payment proofs, or undocumented campaign targeting evidence results in partial or full claim rejection at the documentation review stage.

Incorrect Product Mapping

The Top 3 products benefit from higher caps than additional products. Misclassifying which products qualify as Top 3 — or failing to update the classification — results in cap errors across the claim portfolio.

Development vs. Maintenance

Employment support is available only for new software development, not maintenance, bug fixes, or updates. Misclassifying employee activity without documentation of the new development nature is a documented rejection cause.

Pre-Approval Management

The most operationally critical discipline in the entire system

Categories Typically Requiring Pre-Approval

  • Certain special promotion and event activities
  • Overseas representative unit establishment
  • Overseas HR search and recruitment activities
  • Agency commission arrangements
  • Specific certification programs above threshold
  • Any category where the authority issues updated guidance

Pre-approval requirements are subject to annual revision. Current requirements must be verified before each new spend cycle.

Pre-approval is not a formality. It is a substantive authority review that must precede expenditure in qualifying categories. Applications submitted after spend has been incurred are rejected as a matter of procedure.

The practical implication for any company operating in a pre-approval-required category is that spend planning must be integrated into the application calendar. This requires forward visibility of marketing and operational budgets, which is a governance requirement we build into Tier 3 engagements.

A well-managed pre-approval calendar is one of the most tangible differentiators between a company that recovers the majority of eligible spend and one that forfeits it through procedural failure.

Run your eligibility review.

A Structuring Assessment will confirm whether your company profile qualifies and what the realistic economic impact would be under a compliant structure.

No obligation. We respond within 48 business hours. Not legal or tax advice.

The Firm

LaunchEntities

International Digital Export Structuring and Incentive Optimization for SaaS and mobile app companies with cross-border revenue. Not a paperwork agency. Not a grant consultant. A structuring partner.

Who We Are

Built for the specific complexity of international digital structuring

LaunchEntities is a boutique advisory firm focused exclusively on international operating structure design for digital product companies — SaaS businesses, mobile application studios, and digital platforms generating meaningful cross-border revenue.

We do not maintain a broad corporate services practice. Our focus is deliberately narrow: deep operational knowledge of Türkiye's Digital Export and E-Export Incentive Framework, combined with cross-border tax structuring capability and direct fluency in the unit economics of digital-first businesses.

Our clients are typically founder-led or CFO-managed companies generating €20,000–€200,000 or more in monthly recurring revenue, spending materially on paid acquisition, and distributing through international platforms including Apple App Store and Google Play.

The firms most comparable to what we do are not grant consultants or formation agents — they are international tax advisory boutiques that combine structural design with operational program management. That is the standard against which we hold our work.

Digital Export Architecture Specialists

We work exclusively on international structuring for technology founders. Not general corporate formation, not domestic tax compliance, not EU grant advisory.

Deep Program Fluency

We maintain active coordination with Turkish export authorities, qualified local counsel, and İHKİB to ensure structures remain current with program evolution and regulatory updates.

Cross-Border Tax Integration

We coordinate with qualified counsel in founder home jurisdictions — covering EU, UK, MENA, and other geographies — to ensure every structure is coherent across all relevant tax systems.

Growth Economics Fluency

We understand CAC, LTV, cohort economics, platform margin dynamics, and the capital structure implications of margin improvement. Our structuring recommendations are calibrated to digital business financial realities.

Compliance-First Methodology

Every structure we design is reviewed against OECD BEPS standards, applicable bilateral tax treaties, relevant CFC and PE rules, and Türkiye's program requirements before implementation is proposed.

Compliance and Documentation Standards

The standards we hold our own work to

No Substance-Free Structures

Every entity we establish must operate as a real business with genuine management, real operational decisions, and documentable commercial activity in Türkiye. We will not proceed with a structure designed purely to access incentives without genuine business presence.

OECD BEPS-Standard Transfer Pricing

Intercompany transactions are designed with contemporaneous documentation supporting arm's-length pricing. We do not allow undocumented or post-hoc transfer pricing justifications.

Full Cross-Border Tax Coherence

Every structure must be reviewed for PE and CFC implications in the founder's home jurisdiction before implementation. We do not proceed without a written risk assessment reviewed by qualified counsel in the relevant jurisdiction.

Audit-Survivable Documentation

We build documentation systems that are designed to withstand authority review — not to satisfy minimum requirements. A claim that cannot survive an audit is a liability, not a recovery.

Pre-Approval Discipline

We flag every pre-approval requirement explicitly and build calendar management into our operational engagements. Spend incurred without required pre-approval is not recoverable, and it is our responsibility to prevent this.

No Outcome Guarantees

We do not represent that any structure will result in a specific reimbursement amount, approval rate, or tax outcome. All economic modeling is scenario-based and subject to explicit assumptions. Eligibility determinations rest with the relevant authorities.

Documentation Architecture

The two document sets every compliant structure must maintain

Claim File — Reimbursement Evidence

  • Invoices addressed to the Turkish entity for all claimed expenditure
  • Bank payment confirmations from Turkish entity accounts
  • Campaign screenshots with geo-targeting evidence (international audiences)
  • Platform commission statements from Apple, Google, or equivalent
  • Pre-approval correspondence and authority confirmations where required
  • Product classification documentation (Top 3 vs additional)

Governance File — Substance Evidence

  • Board meeting minutes documenting key commercial and operational decisions
  • Intercompany service agreements, IP license or transfer agreements
  • Transfer pricing documentation with comparable benchmarking
  • Management presence evidence (travel records, communication trails)
  • Registered office substance evidence (lease agreement, operational activity)
  • Pre-approval correspondence and authority responses where applicable
  • İHKİB membership certificates and annual renewals
Structuring Assessment

Request a Preliminary Assessment

We review each submission individually. An assessment is progressed only where there is a credible basis for compliant structuring value. Please provide accurate information — incomplete submissions will not receive a substantive response.

What happens after you submit

We review your submission against program eligibility criteria and your cross-border tax profile. If there is a credible structural fit, we will respond within 48 business hours to schedule a preliminary assessment call.

The call covers: program eligibility, entity design options, honest economic modeling, and a view on the primary risks specific to your situation.

There is no fee for the preliminary assessment call. Our commercial engagement begins with the Strategic Structuring Blueprint (Tier 1).

Criteria for a strong submission

  • Meaningful international revenue (majority outside home country)
  • Monthly paid acquisition spend of €10,000 or more
  • Distribution through App Store, Google Play, or international web channels
  • Founder willing to establish genuine Turkish entity substance
  • No existing non-compliance with current tax obligations

No obligation. We respond within 48 business hours. We do not share your data. Not legal or tax advice.

Assessment Form
Please complete all required fields before submitting.
We respond within 48 business hours. All submissions treated as confidential.

No obligation. We do not share your data with third parties. Not legal or tax advice.

Insights

Analysis and Perspective

Substantive briefings on digital export structuring, cross-border tax risk, program operations, and the economics of margin optimization. Written for founders and CFO-level readers.

Current Articles
Structuring

IP Transfer vs. Exclusive License: A Framework for Digital Export Architecture Decisions

The choice between transferring intellectual property to a Turkish entity and licensing it determines exit tax exposure, ongoing flexibility, transfer pricing complexity, and treaty access. For most digital export structures, this is the single most consequential structural decision. This analysis covers the trade-offs systematically by founder scenario: early stage, pre-exit, and multi-product portfolio companies.

Read Analysis →
Tax Risk

CFC Rules and Turkish Entities: What EU-Resident Founders Need to Understand Before Structuring

German, Dutch, French, and UK controlled foreign corporation regimes each apply differently to Turkish operating entity structures. The passive income tests, threshold rules, and substance exemptions vary by jurisdiction in ways that materially affect whether a Turkish structure creates home-country tax exposure. This briefing maps the key rules by jurisdiction and describes how substance planning affects CFC analysis.

Read Analysis →
Program Operations

Pre-Approval in the E-Export Framework: Categories, Timelines, and the Consequences of Getting It Wrong

Pre-approval is not a bureaucratic formality. For certain spend categories, it is a legal prerequisite for reimbursement eligibility. Spend incurred without required pre-approval is permanently ineligible, with no correction mechanism available. This piece maps which categories currently require pre-approval, what the application process involves, typical processing timelines, and how to build a forward-looking spend governance calendar.

Read Analysis →
Transfer Pricing

Arm's-Length Royalty Rates for Mobile App IP: Benchmarking Approaches and Documentation Standards

A royalty paid between a founder's home-country holding entity and a Turkish operating entity must be defensible under the arm's-length standard in both jurisdictions. Setting this rate requires a documented comparable analysis using recognized transfer pricing methods. This piece covers the profit-based, comparable uncontrolled transaction, and residual profit-split approaches as applied to digital product IP, and describes the documentation standard required to withstand authority review.

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Documentation

The Audit File: What Documentation the Export Support Authority Expects and How to Build a Claim-Ready System

The majority of claim rejections in the digital export program are documentation failures, not structural failures. Companies with eligible spend lose recovery because of missing screenshots, absent payment proofs, or inadequately documented campaign targeting. This piece describes the evidence standards the authority applies at review, how to build a folder structure and collection cadence that produces a complete audit file at submission time, and the five most common documentation errors and how to prevent them.

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Valuation

From Incentive Recovery to Valuation Multiple: How Structural Margin Improvement Compounds in a Digital Exit

The economic case for digital export structuring is not limited to the direct reimbursement received. A structural improvement in gross margin — driven by consistent incentive recovery over a 5-year support period — generates EBITDA expansion that compounds at exit through valuation multiples. This analysis models the relationship between monthly incentive recovery, EBITDA margin improvement, and the revenue and EBITDA multiple implications for a SaaS company at a €5M ARR exit baseline.

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Whitepaper

The Digital Export Structuring Guide for SaaS and App Founders

A structured briefing covering the program framework, eligibility prerequisites, cross-border tax considerations, common structuring errors, and a self-assessment checklist.

Written for founders and CFO-level readers who need to evaluate whether this structure is relevant to their situation before committing time to a formal assessment.

Approximately 24 pages. No sales content. No personal data sold or shared.

The Digital Export Structuring Guide

LaunchEntities — 2025 Edition

  • Program architecture and support category overview
  • Eligibility prerequisites checklist
  • IP model selection framework
  • Cross-border tax risk summary by jurisdiction
  • Common failure modes and how to avoid them
  • Self-assessment scorecard

No obligation. We respond within 48 business hours. We do not share your data. Not legal or tax advice.