Does it matter where the company is actually managed from?

It changes everything. A company does not need its registered office in Turkey to be a full taxpayer here. Having its place of management in Turkey, meaning the place where its operations are effectively gathered and directed, is enough on its own. Where that is established, there is no longer foreign income waiting to be brought home; there is corporate income that should have been declared in Turkey from the outset, and the dividend exemption and foreign tax credit both fall away because each of them assumes the income was foreign.