Turkey’s New Tax Regime: 20 Years Without Tax on Foreign Income
Turkey has adopted one of the most interesting tax regimes of recent years for new residents. The changes relate to Law No. 7582 (7582 sayılı Kanun) and the Income Tax Law No. 193 (193 sayılı Gelir Vergisi Kanunu). The key amendment introduces a new provision - Article Mükerrer 20/D. The law was passed by the Turkish Parliament in May 2026 and is subject to official publication and entry into force in accordance with the procedures established under Turkish legislation.
What is the essence of the benefit?
The new article introduces an exemption from Turkish personal income tax for foreign-sourced income of new tax residents of Türkiye.
Legal wording: “Türkiye dışında elde ettiği kazanç ve iratları yirmi yıl boyunca gelir vergisinden müstesnadır.” In other words, foreign dividends, income from foreign businesses, foreign investment income, certain types of capital gains, and other foreign-sourced income may be exempt from Turkish personal income tax for a period of 20 years. At the same time, income generated within Türkiye is not covered by this exemption.
Who does the benefit apply to?
Key condition: during the last 3 calendar years prior to obtaining tax residency status, the individual must not have had Turkish tax residency or registered domicile (ikametgah) in Türkiye. This requirement is set out in the new Article Mükerrer 20/D. The law also explicitly clarifies that even if the person previously had certain Turkish-source income—such as rental income from real estate or investment income - this alone does not disqualify them from benefiting from the exemption.
How to obtain the benefit?
No separate application procedure has been published yet. However, the law explicitly delegates authority to the Turkish Ministry of Treasury and Finance to issue secondary regulations and clarify the implementation rules: “Hazine ve Maliye Bakanlığı ... usul ve esasları belirlemeye yetkilidir.” It is likely that such procedures will be introduced, as individuals applying the exemption will probably need to obtain a Turkish tax residency certificate for compliance purposes.
The article also states: “yıllık beyanname verilmez.” This means that no separate annual tax return is required for these incomes, and exempt income is not included in the general tax declaration.
When is a person considered a tax resident of Türkiye?
Article 4 of the Turkish Income Tax Law (Gelir Vergisi Kanunu) establishes two independent criteria: having a domicile (ikametgah) in Türkiye or residing in Türkiye for more than 6 months within a calendar year.
Legal wording: “İkametgahı Türkiye'de bulunanlar; Bir takvim yılı içinde Türkiye'de devamlı olarak altı aydan fazla oturanlar.”
In other words, the 183+ days rule is not the only criterion. There is a separate concept of ikametgah.
What is ikametgah and why is it important?
The term ikametgah is used in tax law by reference to Turkish civil law. In essence, it is similar to domicile—the center of vital interests or a permanent place of residence.
Therefore, an important practical question arises: can a person be considered a tax resident of Türkiye while staying there for fewer than 183 days?
Formally - yes, if the tax authority can prove the existence of a substantial connection with Türkiye: a permanent address, family ties, the center of life, living infrastructure, and an actual intention to reside in the country.
However, in practice, the most objective criterion remains physical presence of more than 183 days within a calendar year. At the same time, it is possible that for the purposes of applying the new exemption, Türkiye may in the future introduce a separate, clearer tax residency test- for example, a reduced physical presence threshold, as seen in other jurisdictions: 60 days in Cyprus or 90 days in the UAE, subject to additional conditions. Such an approach would make the regime more predictable for new residents and reduce uncertainty around the application of the ikametgah criterion.
What is important to understand about real estate and residence permits?
Owning real estate in Türkiye alone is unlikely, by itself, to automatically make a person a tax resident.
However, owning property, registering an address, holding a residence permit, actual physical presence, and the center of vital interests may all be assessed together as a combined set of factors.
At the same time, Türkiye already offers relatively accessible migration pathways. In some regions, it is possible to obtain a residence permit through real estate purchase without the $400,000 threshold required for the citizenship-by-investment program.
In practice, this creates an interesting combination: a relatively accessible entry route via real estate, the possibility of obtaining a residence permit, and a new tax exemption regime for foreign-sourced income.
Why could this become important?
Türkiye is gradually forming a model that combines migration options, comfortable infrastructure, and an internationally competitive tax regime. If the implementation of the law proves to be predictable, Türkiye could become an attractive regional hub for individuals seeking a jurisdiction for relocation, business activity, and structuring personal foreign-sourced income.
At the same time, it is expected that holding only Turkish citizenship would not be sufficient on its own to establish tax residency.
Most likely, either actual physical presence of 183+ days will be required, or a shorter period may apply if there is a clearly established center of vital interests in Türkiye.
The practical application of the ikametgah criterion, as well as the possible introduction of a special residency test for the purposes of the new exemption, will be key issues in this emerging regime.
The new regime may be particularly attractive:
- owners of international businesses;
- investors and traders;
- entrepreneurs and founders;
- individuals considering relocation to Türkiye.
The practical application of the new regime is still being developed, so proper structuring of tax residency and foreign-sourced income will be of key importance.
We (the REVERA team) advise clients on international taxation, relocation, and private wealth protection, including:
- analysis of tax residency;
- structuring of foreign assets and income;
- assessment of CFC and CRS risks;
- application of international double tax treaties.
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