Who Is Liable for Environmental Cleaning Tax in Virtual/Shared Offices in Türkiye?

In recent years, rapid technological transformation has reshaped not only how we conduct business but also where we conduct it. One of the most significant outcomes of this shift has been the widespread adoption of virtual and shared office models.

Virtual offices have become a common operational base for startups, remote teams, consultants, and especially foreign nationals establishing companies in Türkiye without maintaining a physical workspace. These models allow companies to obtain a registered business address while benefiting from services such as call handling, mail management, visitor reception, and meeting room usage at relatively low cost.

However, this new-generation working model has triggered legal uncertainty in one specific area, which is the Environmental Cleaning Tax.

Environmental Cleaning Tax in Shared or Virtual Office Models

Environmental Cleaning Tax is regulated under Article 44 of the Municipal Revenues Law.

According to the law, residential units, workplaces, and other buildings located within municipal boundaries and benefiting from municipal cleaning services are subject to Environmental Cleaning Tax. The taxpayer is defined as the person or entity that uses the building in any capacity, and tax liability begins upon usage of the premises.

Based on this interpretation, the Turkish Revenue Administration has taken the position that in cases where multiple unrelated real or legal persons operate within the same building under a virtual office model, each tenant listed in a lease agreement should be considered separately liable for Environmental Cleaning Tax.

This position is reflected in the İzmir Tax Office Directorate’s private ruling dated 27 December 2018.

The Legal Nature of Virtual Office Agreements

Despite the administrative view mentioned above, virtual office arrangements differ significantly from conventional commercial lease relationships.

In most shared office structures:

• Companies do not lease an independent and exclusive office unit.

• The registered address is provided under a service or membership agreement rather than a traditional lease agreement.

• Individual room or office numbers within the building are generally not recognized as separate legal addresses for independent physical occupation.

• Essential services such as electricity, water, cleaning, internet access, reception, and facility management are centrally provided by the virtual office operator.

From a legal standpoint, companies operating under virtual office agreements are not direct tenants of the property owner but rather members or service recipients of the shared office provider.

Therefore, the relationship between the company and the office provider resembles a service subscription rather than a leasehold interest.

Who Should Actually Pay the Environmental Cleaning Tax?

In this structure:

• The actual occupant and beneficiary of municipal cleaning services is the shared office provider as the main user of the premises.

• Virtual office clients do not independently consume or control municipal services within the building.

• Infrastructure-related services are delivered centrally by the operator.

As a result, it is more legally consistent for the Environmental Cleaning Tax liability to be registered under and collected from the virtual office operator rather than the individual companies using the address under membership agreements.

Treating virtual office members as independent workplace tenants through analogy or comparison with traditional leases may not accurately reflect the legal and operational realities of shared office models.

Practical Risks for Foreign Companies in Türkiye

Foreign nationals frequently use shared office addresses as the registered headquarters of their Turkish companies for company incorporation, residence permit applications, or tax registration.

In practice, municipal officers or enforcement units may attempt to impose Environmental Cleaning Tax obligations directly on such companies.

However, such demands may not always reflect the legal nature of the contractual relationship between the company and the shared office provider.

Companies operating under virtual office models should seek legal assistance before accepting or paying any Environmental Cleaning Tax assessed individually in their name.

At Bayraktar Attorneys, we regularly assist foreign investors and companies in resolving tax and municipal compliance issues arising from virtual office usage in Türkiye.

If you have received a municipal notice regarding Environmental Cleaning Tax in connection with your shared office address, you may contact our team for a legal assessment.