⚖️ "Should the holding company be set up in Türkiye or Kazakhstan?"
I hear this question every week. The honest answer: the question itself is framed incorrectly.
Let us look at a real-life example. A group with a trading business: operations in Türkiye, clients across Europe and the CIS, and an owner who wants a single top-tier structure above everything.
Where Türkiye Wins
Operational substance. Genuine banking, an authentic commercial market, and a company from which you can truly manage a business. Plus fresh competitive advantages: a transit regime with an effective tax rate of 1.25%, non-dom status for the owner, and the İFM (Istanbul Financial Center) for financial flows. However, the compliance burden is heavy: audits, SGK, KYC, and regulations that change more frequently than one would prefer.
Where Kazakhstan Wins
Holding architecture. The AIFC operates under English common law with its own independent court: shareholder disputes or asset protection exist within a predictable legal framework that Türkiye cannot guarantee. Yet, it is not the ideal venue for day-to-day operations: the market is smaller, and the maintenance costs outweigh the practical benefits.
The Solution for This Group
Not "either/or," but layered. At the top sits an AIFC holding company, holding equity and capital, with disputes and ownership governed by English law. Below sits an operating company in Türkiye, running the commercial business, leveraging the transit regime and local market. Each jurisdiction performs precisely the role it does best.
An added operational bonus: such an arrangement also serves as insurance. If regulations change in one jurisdiction, the second layer preserves the structure, ensuring any transition does not turn into a crisis.
Takeaway: A jurisdiction is a tool tailored to a specific task, not merely a flag. The question is not "which is better," but "which layer belongs where."
Setting up a corporate structure over Türkiye and the CIS? Reach out to us, and we will map out your operational layers.