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ANALYSIS

Can a Foreign Company Manager Work for Another Company?

One of the most common questions asked by foreign company managers in Türkiye is whether they can take on a role in another company while their current work permit remains valid. The answer is not simply “yes” or “no.” The nature of the role, the position to be held in the second company, whether the individual will perform actual work, the scope of their authority to represent the company, and the conditions of the existing work permit must all be assessed together.

Improperly structured relationships with a second company may lead to significant legal consequences, including violations of work permit regulations, administrative fines, cancellation of the work permit, and negative outcomes in future immigration or work permit applications.

06 June 2026

Reading Time: 8 min

Content

Executive Summary
Can a Foreign Company Manager Work for Another Company?
Which Company Does a Work Permit Cover?
The Difference Between Authority to Represent a Company and Actual Employment
Can a Foreign National Hold Positions in Two Companies at the Same Time?
When Is a New Work Permit Required?
Holding Companies, Corporate Groups and Subsidiaries
Practical Case Examples
Risks and Key Considerations
Frequently Asked Questions
Conclusion

1. Executive Summary

Work permits issued to foreign nationals in Türkiye are granted based on a specific employer, a specific business activity, and a defined employment relationship. Therefore, holding a valid work permit does not automatically entitle a foreign national to work for other companies.

At the same time, not every role undertaken in a second company constitutes a violation of work permit regulations. In some cases, a foreign national may act solely as a shareholder, while in others they may serve as a member of the board of directors. Certain positions involve only the authority to represent the company, whereas others involve the actual performance of work. Distinguishing between these situations is essential in practice.

When planning management structures for investors, holding companies, corporate groups, and international businesses, the analysis should extend beyond corporate law. It is equally important to consider the applicable rules under Turkish immigration law and work permit legislation. Properly structured corporate organizations can operate in compliance with the law, while incorrectly planned management roles or changes in responsibilities may create significant legal risks.

2. Can a Foreign Company Manager Work for Another Company?

As a general rule, an existing work permit does not authorize a foreign national to work for another company. A work permit is issued for a specific employer and is based on the position and duties the foreign national is authorized to perform within that employer’s organization.
Accordingly, the following activities in a second company may require a separate legal assessment:

Working for remuneration;
Performing executive or managerial functions;
Managing day-to-day operations;
Supervising employees;
Conducting sales or commercial activities;
Managing the company’s daily business operations.

However, merely becoming a shareholder of another company or holding certain representative powers does not automatically mean that a separate work permit is required.
The key factor is the nature of the activities that the foreign national actually performs in practice.

3. Which Company Does a Work Permit Cover?

In Türkiye, work permits are assessed based on the following factors:

the employer,
the workplace,
the business activity,
the position,
and the employment relationship.

Accordingly, a work permit issued for Company A does not automatically authorize a foreign national to work as a full-time manager for Company B. From a legal perspective, these are two separate employment relationships.
The fact that both companies are owned by the same shareholders does not necessarily change this conclusion. Since each company has its own separate legal personality, the foreign national’s role in each company may need to be assessed independently for work permit purposes.

4. The Difference Between Authority to Represent a Company and Actual Employment

This is one of the most frequently misunderstood issues in practice. A foreign national may:

be a shareholder of a company;
serve as a company manager;
be a member of the board of directors;
hold signatory authority on behalf of the company.

However, none of these roles necessarily means that the individual is actually performing work within the meaning of Turkish work permit regulations.
For example, a board member who attends strategic meetings a few times a month is not in the same legal position as a general manager who works at the company on a daily basis and is responsible for its day-to-day operations.
The scope of the individual’s authority is important, but equally important is how that authority is exercised in practice.

5. Can a Foreign National Hold Positions in Two Companies at the Same Time?

In certain situations, it is possible. However, the answer depends on several factors, including:

the nature of the role;
the way the foreign national will work for the second company;
the duration of the work;
whether there is a remuneration or compensation arrangement;
the organizational structure of the companies;
the scope and conditions of the existing work permit.

For this reason, accepting a position in a second company is not automatically prohibited. Likewise, it is not automatically permitted.
Proceeding without a professional legal assessment may expose both the foreign national and the companies involved to significant legal and regulatory risks.

6. When Is a New Work Permit Required?

The need for a new work permit application may arise in situations such as:

performing actual work for a new employer;
accepting a paid managerial or executive position in another company;
assuming operational management responsibilities;
managing the company’s day-to-day operations;
supervising or managing employees;
actively carrying out the company’s commercial activities.

Whether a new work permit is required depends on the specific circumstances of each case. The legal assessment should be based on the actual duties performed rather than solely on the job title or corporate designation.

7. Holding Companies, Corporate Groups and Subsidiaries

One of the most common corporate structures encountered in international business is the use of holding companies and corporate groups. When responsibilities are shared between a parent company and its subsidiaries, the arrangement should also be evaluated from the perspective of Turkish work permit regulations.
For example, each of the following situations may lead to a different legal assessment:

a Holding CEO serving in executive roles within one or more subsidiaries;
a Group CFO overseeing the financial management of several companies within the same corporate group;
the same foreign executive being appointed as a company manager in three different legal entities.

Each of these scenarios may have different legal consequences depending on the nature of the duties performed and the scope of the existing work permit.
The fact that companies belong to the same economic group or share the same ownership structure does not, by itself, mean that a foreign national is automatically authorized to work for each of those companies. Since every company is a separate legal entity, work permit compliance should be assessed individually for each role.

8. Practical Case Examples and Legal Analysis

Managing Two Companies Within the Same Holding Group

Case 01

A German investor intends to serve as the company manager of two different limited liability companies operating under the same holding structure in Türkiye. The first company is engaged in manufacturing, while the second is responsible for export operations. The foreign national already holds a valid work permit issued for the first company.

At first glance, it may appear that no additional legal requirements apply because both companies belong to the same corporate group. However, under Turkish work permit legislation, each company is considered a separate employer and a separate legal entity.
Whether the existing work permit is sufficient depends on several factors, including the nature of the foreign national’s responsibilities in the second company, whether they will perform day-to-day management functions, the extent of their authority, and whether they will actively participate in the company’s operations.

If the individual merely attends strategic management meetings and participates in high-level decision-making without being involved in the company’s daily operations, the legal assessment may differ from a situation where they manage employees, sign contracts, oversee business activities, and direct the company’s daily operations.

Aetra Legal Assessment
Holding structures do not automatically create an exception under Turkish work permit regulations. When foreign executives are appointed to positions in multiple companies within the same corporate group, both corporate law and work permit legislation should be assessed together before the appointments become effective.
Providing Consultancy Services to a Second Company

Case 02

A British company executive holds a valid work permit and serves as the General Manager of Company A in Türkiye. At the same time, Company B intends to engage the individual as a strategic growth consultant one day per week. Separate remuneration will be paid for these consultancy services.

In this situation, it would be incorrect to reach a legal conclusion based solely on the use of the term “consultancy.” The scope of the services, their continuity, the remuneration arrangement, and the manner in which the work is actually performed are all relevant factors.

There is a significant legal distinction between attending periodic strategic review meetings and managing a company’s day-to-day operations on a regular basis. If consultancy activities evolve into actual employment or executive management functions, an additional work permit may become necessary.

Aetra Legal Assessment
Companies should not assume that simply structuring a relationship as a consultancy agreement eliminates work permit obligations. Turkish authorities focus primarily on the substance of the relationship rather than its contractual title. The actual nature of the services performed will generally be the determining factor when assessing compliance with Turkish work permit legislation.
A Foreign National Serving as a Member of the Board of Directors

Case 03

A French investor serves as a member of the board of directors of a joint-stock company operating in Türkiye. The individual attends board meetings only once a month and does not participate in the company’s day-to-day operations or management.

In this situation, there is an important legal distinction between merely serving as a member of the company’s governing body and actively managing the company’s daily business.

Board membership alone may not always be regarded as actual employment requiring a work permit under Turkish law. However, the legal assessment may change if the foreign national begins to carry out executive responsibilities or becomes involved in the company’s day-to-day operations.

Aetra Legal Assessment
Membership on the board of directors and executive management are not legally identical concepts. Whether a work permit is required depends on the specific facts of each case, particularly the nature of the individual’s actual duties and level of involvement in the company’s operations.
Establishing a Second Company

Case 04

A foreign investor has established a second technology company in addition to the first company in which they operates under a valid work permit. The investor is also planned to be appointed as the manager of the new company.

One of the most common mistakes made by investors is assuming that the existing work permit automatically applies to the newly established company as well.

However, the new company has a separate legal personality. Therefore, a separate assessment may be required from the perspective of work permit regulations.

The mere completion of the company’s incorporation does not, by itself, mean that the foreign national is entitled to work in the new company.
Holding Positions in Three Companies Simultaneously

Case 05

A foreign executive is registered as a manager in three different companies located in Türkiye. One company operates in manufacturing, another in software, and the third in logistics.

If the foreign executive actively performs duties in each company, serious legal risks may arise in terms of work permit requirements.

In such structures, the organisational chart, distribution of duties, and the foreign national’s actual working model should be analysed in detail.

9. Risks and Key Considerations

The scope of the existing work permit should be carefully reviewed.
The allocation of responsibilities between the companies should be clearly defined in writing.
Actual employment should not be confused with the authority to represent a company.
The allocation of responsibilities within holding companies and corporate groups should be planned separately.
A legal assessment should be carried out before assuming a new position.
A violation of work permit regulations may also affect future applications.

10. Frequently Asked Questions

11. Aetra Legal Perspective
At Aetra Legal, we evaluate work permit matters for foreign investors and international companies in Türkiye from a broader perspective rather than focusing solely on the application process. Our approach takes into account the company’s organisational structure and long-term business growth strategy.

When company structuring, executive appointments, the allocation of responsibilities among group companies, and work permit strategies are planned together, businesses can achieve compliance with applicable legislation while significantly reducing potential legal risks in the future. This integrated approach helps international companies manage their operations in Türkiye in a more secure and sustainable manner.

12. Conclusion

Whether a foreign company manager may take on a position in another company is not a question that can be answered with a single rule. The scope of the existing work permit, the nature of the role in the second company, the existence of actual employment, and the legal relationship between the companies should all be assessed together.

Particularly in the case of international investors, holding companies, and multi-company corporate structures, inadequate planning may affect not only the current work permit but also future work permit and residence permit applications. For this reason, carrying out a legal assessment before assuming an additional position is essential for structuring the process correctly.