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.
RS/RSUs awarded 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.
Technically, the sale or resale 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 RS/RSUs is based on objective criteria (i.e. performance or job category) and there is no reimbursement by subsidiary/local deduction, the benefit should not be considered part of an employee's salary.
Written disclaimer recommended to reduce risk of plan entitlement.