Türkiye's 20-Year Foreign Income Tax Exemption Under Law No. 7582

What Law No. 7582 Introduced

On 4 June 2026, Türkiye published Law No. 7582 (Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun) in the Official Gazette (Resmî Gazete) No. 33270. Among a broader package of amendments, the Law inserted a new provision, repeated Article 20/D (Mükerrer Madde 20/D), into Income Tax Law No. 193 (Gelir Vergisi Kanunu, "GVK"). The provision allows qualifying individuals who newly become Turkish tax residents to exclude their foreign-source income from the Turkish income tax base for a period of up to twenty years.

The implementing rules were set out in Income Tax General Communiqué Series No. 333 (Gelir Vergisi Genel Tebliği Seri No. 333), published in the Official Gazette No. 33300 on 4 July 2026, which explains the procedures and principles the Revenue Administration (Gelir İdaresi Başkanlığı, "GİB") applies. This article is a general legal analysis of the framework as enacted; it is not tax advice and does not address any individual's facts. Eligibility and cross-border consequences are assessed case by case.

At its core, GVK Mükerrer Article 20/D provides that a natural person who becomes a Turkish tax resident, and who in the three calendar years preceding that residency had neither a domicile (ikametgah) nor a tax liability in Türkiye, may keep foreign-source income and earnings outside the scope of Turkish income tax for twenty years. Three features define the measure: it is a residency-triggered exemption rather than a citizenship benefit; it is prospective and time-limited, applying to persons treated as resident in Türkiye from 1 January 2026 for a defined twenty-year window; and it is scope-limited to foreign-source income, with Turkish-source income taxed under general rules.

The Legal Basis: Law No. 193, Law No. 7582, and Communiqué No. 333

The exemption sits inside an existing statutory architecture rather than replacing it, and precision matters. Income Tax Law No. 193 (GVK), dated 31 December 1960, is the foundational statute governing individual income taxation; it defines who is a taxpayer and the difference between full and limited tax liability. Law No. 7582, published in Resmî Gazete No. 33270 on 4 June 2026, is the amending law that inserted Mükerrer Article 20/D into the GVK and amended the Inheritance and Transfer Tax Law (Law No. 7338) in connection with it; it entered into force on publication and applies to those treated as resident from 1 January 2026. Income Tax General Communiqué Series No. 333, published in Resmî Gazete No. 33300 on 4 July 2026, is the secondary legislation setting out how the Revenue Administration applies the exemption, including the treatment of tax returns and the non-deductibility of related expenses.

Reading these three instruments together (the base law, the amendment, and the communiqué) is what determines whether a given individual falls within the exemption. Isolated readings of any single source can be misleading.

Who Qualifies: The Prior Three-Year Non-Residency Condition

The central gatekeeping condition is the prior three-year rule. To fall within Mükerrer Article 20/D, the individual must, in the three calendar years before becoming a Turkish tax resident, have had neither a domicile nor a tax liability in Türkiye. In practical terms this is an anti-abuse "freshness" test: the exemption is designed for genuinely new arrivals to the Turkish tax base (individuals relocating their residence to Türkiye) rather than for existing or recently-departed Turkish taxpayers seeking to reset their status.

Two points frequently require careful analysis. First, "tax liability" is a status question, not merely a payment question: whether an individual had a Turkish tax liability in the look-back period depends on their residency status and income sources during those years. Second, the look-back is measured in calendar years, so the date on which residency is established, and therefore where the three-calendar-year window falls, can materially affect eligibility. Because the condition turns on the individual's documented history, whether it is satisfied is a matter for individual review rather than a general answer.

What Income Is Covered, and What Is Not

The exemption is framed around the source of the income rather than its category. The provision does not carve out particular income types; the defining question is whether the income is foreign-source (yurt dışı kaynaklı). Accordingly, foreign-source items across the GVK income categories can, in principle, fall within scope where the conditions are met:

• Foreign employment income for services performed abroad
• Foreign self-employment and professional income
• Foreign business income
• Foreign investment income (dividends, interest, coupon income)
• Foreign immovable-property income (rental income from property abroad)
• Foreign capital gains, such as gains on the disposal of foreign participations

Whether a specific stream is genuinely foreign-source (as opposed to Turkish-source income merely paid from abroad) is a legal characterization question, and it is where careful analysis is required. The exemption does not make its beneficiary tax-free in Türkiye. Turkish-source income remains fully taxable under ordinary GVK rules. Expenses relating to exempt income are not deductible, and foreign taxes on exempt income cannot be credited in Türkiye, consistent with the principle that exempt income is removed from the Turkish base entirely. Filing obligations are not automatically eliminated: under the Communiqué No. 333 approach, income within the exemption is not declared in the annual return, but where an individual has other income (for example Turkish-source income) requiring a return, that return excludes the exempt foreign income.

How Turkish Tax Residency Is Established (GVK Articles 3 and 4)

The entire regime depends on a threshold question: is the individual a Turkish tax resident at all? This is governed by the GVK, not by immigration or citizenship law. GVK Article 3 provides that natural persons resident in Türkiye ("full taxpayers", tam mükellef) are taxed on their worldwide income, whether earned inside or outside Türkiye. GVK Article 4 defines who is resident: residency is established either by having a domicile (ikametgah) in Türkiye within the meaning of the Turkish Civil Code (Law No. 4721), or by continuous residence in Türkiye for more than six months in a calendar year. The two tests apply in the alternative: meeting either is sufficient.

It is precisely because Turkish residents are taxed on worldwide income under Article 3 that Mükerrer Article 20/D matters: without the exemption, a new resident would bring their global income into the Turkish base. Establishing, or deliberately not establishing, Turkish tax residency is therefore the pivotal planning question, and it must be coordinated with the individual's home-country rules, because two jurisdictions may each assert residency over the same person.

Turkish Citizenship Is Not Turkish Tax Residency

This distinction is the single most frequently misunderstood point. Turkish citizenship, acquired under Citizenship Law No. 5901, does not by itself make a person a Turkish tax resident. Citizenship and tax residency are independent legal statuses governed by different laws. A person can hold Turkish citizenship while remaining a non-resident for Turkish tax purposes (taxed only on Turkish-source income as a limited taxpayer), or be a Turkish tax resident without being a citizen (for example, a foreign national who satisfies the Article 4 residency test).

For an investor who obtains Turkish citizenship through the investment route, the tax consequences flow from where they are tax resident, determined under GVK Articles 3 and 4, not from the passport. The 20-year exemption is likewise a tax-residency benefit: acquiring citizenship neither grants it automatically nor is required to claim it. What matters is the individual's residency status and their prior three-year history. Because citizenship and tax residency move on separate tracks, structuring one without analyzing the other can produce unintended results, which is why the two questions are best assessed together.

The 1% Inheritance and Gift Tax Provision

Law No. 7582 also amended the Inheritance and Transfer Tax Law (Law No. 7338) to provide that, for individuals benefiting from the income tax exemption under Mükerrer Article 20/D, transfers occurring by inheritance during the exemption period are taxed at a rate of 1%. As with the income exemption, the inheritance provision is conditional and fact-dependent, and its interaction with the deceased's and heirs' home-country succession and estate-tax rules must be considered separately.

How This Interacts With Citizenship by Investment

Turak Law's core practice is Turkish Citizenship by Investment: principally the bank deposit pathway (a qualifying deposit held with a Turkish bank) and the real estate pathway (qualifying property acquisition). Law No. 7582 is relevant to many such clients, but the relationship must be framed correctly. The two decisions are distinct: acquiring Turkish citizenship is a nationality decision under Law No. 5901, while whether and when to become a Turkish tax resident is a separate decision under the GVK. An investor may pursue citizenship without becoming Turkish tax resident, may relocate and become resident, or may do both in a deliberate sequence.

The exemption can make relocation more attractive for genuinely new residents who satisfy the prior three-year condition, because it addresses the worldwide-income exposure that Article 3 would otherwise create. Sequencing and timing require analysis, because when residency is established affects both the three-calendar-year look-back and the running of the twenty-year window. This is a natural point at which citizenship planning and tax-residency planning meet, and where coordinated advice tends to serve the client. Related reading on this site includes the Turkish Citizenship by Bank Deposit and Real Estate pathway pages and the Citizenship by Investment overview.

Who Benefits Most

Without overstating what any individual will achieve, the profile of person for whom Mükerrer Article 20/D is most relevant typically shares several features: a genuinely new arrival to the Turkish tax base who can satisfy the prior three-year non-residency condition; meaningful foreign-source income (such as foreign business or professional income, foreign investment income, or foreign rental income) that would otherwise enter the Turkish worldwide-income base once residency is established; a willingness to actually establish Turkish tax residency under Article 4, as opposed to holding citizenship while remaining non-resident; and home-country rules that permit an efficient change of residence without disproportionate exit or continuing-taxation consequences. Whether an individual actually fits this profile, and what it would mean in their home jurisdiction, is exactly what a consultation is for.

What to Verify Before Acting

A responsible analysis of this regime does not stop at Turkish law. Before relying on the exemption, the following must be examined for each individual, with Turkish counsel typically coordinating with the client's home-country advisors on the non-Turkish elements: home-country tax residency and exit taxes, since leaving one jurisdiction can trigger exit charges or continuing obligations; Controlled Foreign Company (CFC) and anti-deferral rules, which may tax the individual on foreign-company income irrespective of the Turkish exemption; Double Taxation Agreement (DTA) tie-breakers, which determine treaty residence where two states each claim residency; the source-versus-residence characterization of specific income; documentation of the prior three-year history; and timing, because the date residency is established affects both the look-back period and the exemption window.

How Turak Law Assists

Turak Law provides legal analysis and representation on the Turkish-law dimensions of the new-resident regime: how GVK Mükerrer Article 20/D, the residency tests in GVK Articles 3 and 4, and Communiqué No. 333 apply to an individual's circumstances, and how these questions interact with a citizenship-by-investment file where relevant. Timelines and any dealings with government offices are subject to the workload and discretion of the relevant Turkish authorities and are not within attorney control. Home-country tax matters are handled in coordination with the client's own advisors in that jurisdiction. The firm has focused on Turkish Citizenship by Investment since 2019. To assess how Law No. 7582 applies to your situation, an individual consultation with Attorney Abdulsamed Burak Turak is available by appointment.

Frequently Asked Questions

Do I pay tax on foreign income in Türkiye?

As a rule, Turkish tax residents ("full taxpayers") are taxed on their worldwide income under Article 3 of Income Tax Law No. 193. However, Law No. 7582 added Mükerrer Article 20/D, which allows qualifying new tax residents to keep foreign-source income outside the Turkish income tax base for up to twenty years if the conditions are met. Non-residents are generally taxed only on Turkish-source income. Individual analysis is required.

Does Turkish citizenship make me a tax resident?

No. Turkish citizenship (Law No. 5901) and Turkish tax residency are independent statuses. Tax residency is determined under GVK Article 4 (by domicile in Türkiye or by continuous residence exceeding six months in a calendar year), not by holding a passport. A citizen can be a non-resident, and a non-citizen can be a tax resident.

Who qualifies for Türkiye's 20-year tax exemption?

An individual who becomes a Turkish tax resident and who, in the three calendar years before becoming resident, had neither a domicile nor a tax liability in Türkiye. The regime applies to persons treated as resident from 1 January 2026 onward. Eligibility is fact-specific.

What is the prior three-year rule in Law No. 7582?

It is the condition that the individual must not have had a Turkish domicile or a Turkish tax liability in any of the three calendar years preceding the year they become Turkish tax resident. It is an anti-abuse test designed to limit the exemption to genuinely new arrivals.

What income is covered by GVK Mükerrer 20/D?

The exemption is defined by the source of the income rather than its category. Foreign-source income across the income categories (for example foreign employment, professional, business, investment (dividends, interest), rental, and certain capital gains) can fall within scope where conditions are met. Turkish-source income is not exempt.

Do I still have to file a Turkish tax return if my foreign income is exempt?

Under the Communiqué No. 333 approach, exempt foreign income is not declared in the annual return; but if you have other income (for example Turkish-source income) that requires a return, that return is filed excluding the exempt foreign income. Filing obligations are fact-specific.

Can a citizenship by investment applicant get the 20-year exemption?

Not automatically. The exemption is a tax-residency benefit, not a citizenship benefit. A CBI applicant obtains it only if they actually become a qualifying new Turkish tax resident and satisfy the prior three-year condition. Citizenship is neither sufficient nor strictly required to claim it.

When did Law No. 7582 take effect?

Law No. 7582 was published in Official Gazette No. 33270 on 4 June 2026 and entered into force on publication, applying to persons treated as Turkish tax resident from 1 January 2026. Its implementing Communiqué (Series No. 333) was published in Official Gazette No. 33300 on 4 July 2026.

What is the 1% inheritance tax under the new law?

Law No. 7582 amended the Inheritance and Transfer Tax Law so that, for individuals benefiting from the Mükerrer Article 20/D income exemption, transfers by inheritance during the exemption period are taxed at 1%. Conditions and home-country succession rules must be considered separately.

What should I check in my home country before relying on the exemption?

At minimum: home-country tax residency and any exit taxes, Controlled Foreign Company (CFC) rules, and the tie-breaker rules of any applicable Double Taxation Agreement. These are assessed with your home-country advisors alongside Turkish counsel.

This article provides general information on Turkish law and does not constitute tax or legal advice or create an attorney-client relationship. Eligibility under Law No. 7582 depends on individual facts and on home-country rules assessed separately.