Criteria | TIFC | DIFC | AIFC | IFC Istanbul |
Presence requirements | To be determined | Moderate Legal entity or branch, physical office / legal address and adequate staffing in the free zone | Moderate Registered office / legal address required; substance requirements depend on activity and regulatory status | High Participant certificate, physical office in the IFC and relevant sector licenses / permits |
Applicable law | Proprietary TIFC law English common law fills gaps | Proprietary DIFC law English common law fills gaps | English common law | Turkish law |
Independent court | ✓ | ✓ | ✓ | ✘ |
International arbitration | ✘ | ✓ | ✓ | Limited |
May holding companies / SPVs become residents | ✓ | ✓ | ✓ | Limited |
Redomiciliation | Currently not provided | ✓ | ✓ | Limited |
Digital assets | ✓ | ✓ | ✓ | Limited |
International exchange infrastructure | Currently not provided | Nasdaq Dubai | AIX | Borsa Istanbul |
Talent / visa regime | Up to 5-year visas for employees and family members Foreign hires allowed without work permit confirmation | Work visas and Emirates ID generally issued for 2 years, with extension Visa quotas linked to office size | Up to 5-year visas for employees, investment residents and families Foreign hires allowed without work permit confirmation | Simplified work permit process for foreign employees of IFC participants and eligible treasury centers |
Criteria | TIFC | DIFC[2] | AIFC | IFC Istanbul[3] |
CIT | ✓ Exemption on financial services for qualified TIFC Participants (✘ digital assets) | 9% rate, with a 0% rate on taxable income up to AED 375,000 0% rate can be applied to a Qualifying Free Zone Person (QFZP) | ✓ Exemption on financial services for AIFC Participants (✘ digital assets) | ✓ 100% CIT deduction on income from export of financial services until 2047 |
✓ Exemption on “Additional” services (audit, other) for TIFC Participants | ✓ Exemption for auditing as well as accounting, legal, consulting services rendered to AIFC Bodies / Participants (financial services providers) | ✓ Additional incentives for qualifying treasury centers | ||
VAT | ✓ Exemption on all services of TIFC Participants | 5% rate 0% rate or exemption may apply to certain supplies, including financial services | ✘✓ Exemption on financial services for AIFC Participants | ✘ No specific IFC incentives (standard VAT rate: 20%) |
PIT | ✓ Exemption for non-resident employees of TIFC Bodies / Participants ✓ Exemption for investment resident on non-uzbek sourced income | - | ✓ Exemption for non-resident employees of AIFC Bodies/ Participants ✓ Exemption for investment resident on non-kazakh sourced income | ✘✓ 60%- 80% of income exempt from PIT for qualified foreign workers |
Capital gain (CIT/PIT) | ✓ Exemption on securities listed on Stock Exchange / shares of TIFC Participants | 0% for QFZP / Participation Exemption | ✓ Exemption on AIFC-listed securities / shares of AIFC Participants | ✘ No specific IFC incentives (general Turkish tax rules apply; generally 25% CIT or up to 40% PIT) |
Dividends (CIT/PIT) | ✓ Exemption on dividends from securities listed on Stock Exchange / shares of TIFC Participants | 0% for QFZP / Participation Exemption | ✓ Exemption on dividends from AIFC-listed securities/shares of AIFC Participants | ✘ No specific IFC incentives (general Turkish tax rules apply; dividend distributions are generally subject to 15% WHT) |
Property and land tax | ✓ Exemption on facilities of TIFC Bodies / Participants within TIFC | - | ✓ Exemption on facilities of AIFC Bodies / Participants within AIFC | ✘ No specific IFC incentives (general property tax rules apply; generally 0.1%-0.6%) |
RC VAT | ✓ Services to TIFC Bodies / Participants are not considered a VAT turnover | 5% 0% rate or exemption may apply to certain supplies | ✓ Services to AIFC Bodies / Organizations are not considered a VAT turnover | ✘ No specific IFC incentives (general Turkish VAT rules apply; standard rate 20%) |
Customs duties | ✓ Exemption from customs duties and fees on goods imported for use or consumption within the TIFC | ✓ Goods imported, produced, stored, or used within DIFC are exempt from customs duties | ✘ No specific incentives for AIFC Customs duties applied in accordance with the EAEU customs regulations | ✘ No specific incentives for IFC |
Duration | January 2076 for tax and customs incentives, ! No specific end date for VAT, RC VAT, property and land tax | - | January 2066, No specific end dates for VAT, RC VAT, property and land tax | Different duration dates |
Conditions to apply | − Registration as TIFC Participant − Licensing requirements for financial services − etc. | QFZP conditions: − Derives qualifying income − Complies with de minimis requirements − Maintains adequate substance in FZ − Has not elected to be subject to CT − Complies with TP requirements − Has prepared audited financial report If any of conditions are not met during the tax period, taxable person shall cease to be a QFZP from the beginning of the tax period and for the next 4 tax periods | Substantial Presence Rules: − May apply to certain AIFC tax exemption − CIGA (or core-income generating activities) carried out in the AIFC − Adequate operating expenses and qualified personnel | − IFC Participant Certificate − Physical presence within the IFC − Compliance with applicable substance requirements − Provision of qualifying services to non-residents where required |
KEY LESSONS FROM OTHER IFCS
Market Development Potential Challenges
Institutional and Regulatory Challenges
IFCS MARKET POSITIONING AND COMPETITIVE ADVANTAGES
CONTACTS
Dilovar Mavlonov
Managing partner
+998 90 069 94 34
Kamoliddin Babaev
Director, Consulting, Technology & Transactions
kamoliddin.babaev@beone-uz.com
+998 93 237 7737
+998 94 655 04 44
Maria Burtseva
Director, Accounting, Tax & HR Compliance
+998 90 939 17 46
Khurshida Artikhodjaeva
Manager, Law Consulting
khurshida.artikkhodjaeva@beone-uz.com
+998 93 550 00 99