TLDR:
Girişim Sermayesi Yatırım Fonu (GSYF, Venture Capital Investment Fund) is Türkiye’s regulated investment vehicle for venture capital, supervised by the SPK under specific tebliğ provisions. GSYFs combine the economic structure of international VC funds with Turkish regulatory framework and significant tax advantages, making them the standard vehicle for institutionally-managed VC capital in Türkiye.
GSYF Structure
A GSYF is established by a portfolio management firm (kurucu, “founder/manager”) as a contractually-organized investment vehicle (similar to a unit trust structure). Key participants: kurucu (the managing firm—must be SPK-licensed portfolio management firm with capital adequacy requirements), katılımcı (the participants/investors—both institutional and high-net-worth individual qualified investors), saklayıcı (the custodian/depositary—a bank or specialized custodian licensed by SPK). The fund is structured under a Fund Bylaws (İçtüzük) and offering document (İhraç Belgesi).
Investment Framework and Restrictions
GSYFs face specific investment restrictions designed to channel capital into Turkish venture investment: minimum 80% of fund assets must be invested in qualifying Turkish “girişim şirketleri” (venture companies—defined by size, age, and operations criteria), maximum 25% concentration in a single investee, investments must be in primary issuances (not secondary), and various other portfolio diversification rules. Foreign investments are limited (typically up to 20% of fund assets), keeping GSYFs primarily Turkish-focused.
Tax Advantages and Recent Reforms
The principal driver of GSYF adoption is significant tax advantage: GSYF distributions to qualified Turkish investors are typically exempt from income tax (under specific conditions in the income tax law), allowing institutional and HNW investors to access VC returns more efficiently than direct investment. GSYF capital gains on exits are exempt under specific holding-period conditions. Combined with the underlying portfolio companies’ R&D and technology investment incentives, GSYF structures can be highly tax-efficient for Turkish investors. Major GSYFs include those managed by Aksoy Ventures, Hedef Portföy, Albaraka Portföy, and many others. GSYFs have grown from <1B TL in early 2010s to significant portion of Turkish institutional VC capital today.