Tax on the spread at exercise.

Tax on sale.

Yes, if subsidiary reimburses parent under a written reimbursement agreement.

Income Tax:
No, unless subsidiary reimburses parent.

Social Insurance Contribution:
No, unless subsidiary reimburses parent.

Stock options granted to employees resident in Türkiye by non-resident companies are exempt from the regulatory approval requirement provided that (1) the sale of shares does not take place in Türkiye; (2) information distributed to employees does not give the impression that the award is a public offering; and (3) no other action that would qualify as a public offering is undertaken.

If funds are remitted out of Türkiye to exercise options, the funds must be remitted through a bank licensed in Türkiye. Additionally, employees must remit a report to the Ministry of Commerce regarding any cross-border transfer of funds in connection with the exercise. If transfers out of the country exceed a certain threshold, they may trigger a report to the Central Bank.

Technically, the sale of shares traded on exchanges outside of Türkiye by Turkish residents must be conducted through an intermediary institution licensed in Türkiye.

Provided the grant of options is based on objective criteria and there is no reimbursement by subsidiary/local deduction, the benefits should not be considered part of an employee's salary.

Written disclaimer recommended to reduce risk of plan entitlement.

Written consent to the collection, use and transfer of data abroad is recommended.