GENERAL INFORMATION REGARDING MICRO EXPORT
GENERAL INFORMATION REGARDING MICRO EXPORT
Micro export is an export model that enables the simplified export of shipments, where the gross weight does not exceed 300 kg and the total value does not exceed 15,000 Euros, within the scope of the Simplified Customs Declaration (SCD), formerly known as the Electronic Commerce Customs Declaration (ECCD), you may frequently encounter. Compared to traditional export procedures, it involves fewer documents and bureaucratic steps. Once the products are delivered to authorized courier companies, the SCD is issued by the courier companies.
The relevant part of Article 225/1 of the Customs Act numbered 4458 states that “The Postal Services or the express cargo carrier companies may be authorized as indirect representative for the proceeding and finalization of the assigning of a Customs-approved treatment or use to the goods which were brought in or consigned by mail and express cargo carriage, and whose amount and value will be determined by the Presidency.” Therefore, in micro export, there is no need for a customs broker, and the procedures are carried out by authorized courier companies (such as DHL, UPS, FedEx, PTT, etc.).
It is crucial to accurately determine the product’s Customs Tariff Statistical Position (CTSP) codes, issue invoices under code 301, and deliver the products to authorized courier companies.
Tax Status of Shipments Within the Scope of Micro Export
Article 11 of the Value Added Tax (VAT) Act numbered 3065 currently in force (the “Act”) exempts export transactions from value added tax (VAT). According to this provision, when a product manufactured or procured in Türkiye is sold abroad, the sale is carried out with 0% VAT, meaning it is exempt from VAT. While products sold within Türkiye are normally subject to 20% VAT, the applicable rate for e-export is 0%. This is stated in the Act’s relevant provision as “Export deliveries and the services related to these deliveries are exempt from VAT.” This enables exporters with more competitive sales and exempts them from the VAT burden that applies to buyers within Türkiye.
An important issue to be considered here is the VAT refund. While producing or procuring their products, businesses are required to pay VAT on various items such as raw material purchases, cargo services, packaging expenses, warehouse rental, and logistics operations, etc. At this point, Article 32 of the Act becomes applicable and provides exporters with the opportunity to claim a VAT refund. Specifically:
“The value added tax incurred due to deliveries and services falling within the scope of Articles 11, 13, 14, 15, and 17 of this Act, which cannot be eliminated through deduction, shall be refunded to the taxpayer.”
In other words, even if an exporter carries out its sales without VAT, they may still claim a refund from the state for the VAT paid during production or logistics processes. This practice alleviates the financial burden on businesses and allows them to compete in international markets with more competitive prices. While submission of a traditional customs declaration is normally required to benefit from a VAT refund, for micro export, the submission of the SCD and documentation of the related expenses shall be considered sufficient. If the submitted documents are deemed appropriate following the application to the tax office, the VAT amount paid by the exporter is refunded to their bank account.
The above general information regarding the VAT exemption and refund has been provided; however, in terms of monitoring the relevant process and complying with procedural requirements, we recommend that the process be supported by professional tax consultancy services.
Legal Status of Government Supports and Incentives
Certain supports are set forth in the relevant provisions of the Circular on E-Export Supports (the “Circular”) dated December 3, 2024, which was issued within the scope of the Decision on E-Export Supports that was put into force by the Presidential Decree numbered 5986 and dated August 24, 2022. It should be noted that the said supports are intended for electronic commerce service provider companies that conduct retail sales through their own branded e-commerce website, generate at least two-thirds of their total sales revenue online, and have their corporate headquarters located in Türkiye.
Under normal circumstances, it is not required to be a member of any exporters’ association to engage in micro export; however, beneficiaries who wish to benefit from the relevant support must be members of an exporters’ association. This is because exporters’ associations are the reviewing authority to which support applications are to be submitted.
The aforementioned supports are as follows:
a. Digital Marketplace Promotion Support
Pursuant to Article 13 of the Circular, within the scope of this support, a portion of the digital advertising expenses incurred by companies, e-export consortia, and retail e-commerce websites through foreign online marketplaces shall be reimbursed. For expenses not exceeding 20% of the sales generated by such advertisements, a 50% support rate shall be applied for a period of three (3) years per marketplace. Depending on the applicant company’s tier, the annual support amount may not exceed TRY 7,500,000, TRY 15,000,000 for retail e-commerce websites, and TRY 25,000,000 for e-export consortia.
While expenses related to pay-per-click (PPC) advertising, display advertisements, and product review services on foreign online marketplaces are eligible for support, expenses such as commissions, membership fees, and indirect taxes are excluded from the scope. In order to benefit from the support, it is mandatory to include the Global Trade Item Number (GTIN) information, the place of origin (country of production), and the registered trademark information when listing products on foreign marketplaces. Prior approval must be obtained for applications, and support payment requests must be submitted on a quarterly basis along with the relevant expenditure documents.
b. E-Export Promotion Support
Within Article 14 of the Circular’s scope, e-export consortia, retail e-commerce websites, B2B platforms, and marketplaces may receive support for marketing-related expenses as determined by the Ministry of Trade (the “Ministry”). For each country, 50% of the marketing expenses shall be supported for a period of three (3) years. The annual support amount may not exceed TRY 4,000,000 for B2B platforms, TRY 15,000,000 for e-export consortia, TRY 25,000,000 for retail e-commerce websites, and TRY 30,000,000 for marketplaces.
Shopping promotions, social media campaigns, and influencer collaborations are within the support’s scope. Promotional activities should be focused on foreign markets and in foreign languages. Supplying businesses that do not manufacture the product must prove this with documents such as invoices or supply agreements. Following prior approval, the support application may be submitted, and the advertising expenses incurred within the support’s scope must be documented and submitted during the specified period.
c. Order Fulfillment Service Support
Under Article 15 of the Circular, 50% of the order fulfillment service costs incurred by companies, e-export consortia, retail e-commerce websites, and marketplaces shall be supported, provided that such services do not exceed 10% of their e-commerce sales in the target country. This support shall be granted for a maximum period of three (3) years per country.
Fulfillment services and warehousing expenses for orders abroad are supported by up to 10% of the total e-commerce sales. The companies providing order fulfillment services must be approved by the Ministry. To apply for the support, prior approval must be obtained, and the expenditure documents must be submitted to the reviewing authority on a quarterly basis.
d. Warehouse Rent Support
Article 16 of the Circular stipulates that the foreign warehouses’ rental expenses, that are rented to ensure product delivery and manage return processes, shall be covered at a rate of 50% per unit, for a maximum period of three (3) years per country, up to an annual limit of TRY 5,000,000. Support for such rental expenses may be granted for up to a maximum of 25 units.
While the net rental cost and expenses related to common use areas are covered under the support, commissions, taxes, and other fees are excluded from the scope. To benefit from the support, the warehouse lease agreement and payment documents must be submitted. The Ministry’s overseas representative shall review the warehouse in question and assess the support’s eligibility. Once approved, the expenditure documents must be submitted within specified periods.
e. Marketplace Integration Support
Marketplace Integration Support is regulated under Article 17 of the Circular. Within the support’s scope companies, e-export consortia, retail e-commerce websites and marketplaces, may receive support for expenses incurred for integration with foreign online marketplaces. For each marketplace, expenses incurred for integration shall be covered at a rate of 50%, for a maximum of six (6) marketplaces, and for a period of three (3) years. A maximum of TRY 200,000 may be granted per integration.
API, ERP, and other integrator services used in the integration processes are eligible for support. The service providers offering integration services must be approved by the Ministry. After submitting the prior approval application, the documents required for the support payment process must be submitted within the specified period.
f. Support for Services Obtained from Online Stores and E-Commerce Stakeholders in the Target Country
Within this support’s scope which is regulated under Article 18 of the Circular, expenses incurred by e-commerce websites and e-export consortia for opening online stores on abroad marketplaces in target countries, as well as for services procured from e-commerce stakeholders in those countries, shall be reimbursed at a rate of 50% for a maximum of three (3) years per country. E-export consortia may receive support up to TRY 3,000,000 annually, while other beneficiaries may receive support up to TRY 1,500,000 annually.
Store opening, design, management, and related consultancy expenses are eligible for support. Services obtained from foreign e-commerce stakeholders may also be included in the scope of support, subject to certain rates. In order to benefit from the support, a store must be opened in the relevant marketplace, and activities must be carried out per the procedures determined. Prior approval must be obtained, and payment applications must be completed within the specified period.
g. Marketplace Commission Expense Support
Article 19 of the Circular, regulating this expense support, stipulates that the commission expenses incurred by e-export consortia, retail e-commerce websites, and companies on foreign marketplaces shall be supported at a rate of 50% for a maximum period of three (3) years. The annual support limit shall be set at TRY 750,000 depending on the company’s tier, TRY 2,500,000 for retail e-commerce websites, and TRY 3,000,000 for e-export consortia.
Commission fees paid to foreign marketplaces are supported; however, membership fees, taxes, and additional service charges are excluded from the scope. During product listing, it is mandatory to enter GTIN information, the country of origin, and the brand information. After submitting the pre-approval application, the expenditure documents for the support payment process must be submitted within the specified period.
In order to benefit from this support, the necessary prior approval applications must be submitted, the expenditure documents must be presented in full, and the support payment applications must be completed within the specified periods.
Conclusion
Micro export provides a simpler and faster process compared to traditional export procedures, making it particularly easier for small and medium-sized enterprises to access foreign markets. Owing to tax benefits as well as various government-provided incentives and support mechanisms, micro export is an effective export model that reduces costs and boosts competitive strength.
However, conducting these processes accurately and effectively within the legal framework is crucial for fully benefiting from the available advantages and for preventing potential legal and administrative risks. From customs clearance to VAT refunds, from support applications to incentive tracking, careful planning at every stage and seeking expert assistance, when necessary, will ensure that micro export becomes a sustainable growth tool.