20-Year Foreign Income
Tax Exemption Framework
Law No. 7582 (Resmi Gazete No. 33270, June 4, 2026) added Mükerrer Article 20/D to Income Tax Law No. 193, exempting new Turkish tax residents from income tax on foreign-sourced earnings for twenty years. The implementation circular (Tebliğ Seri No. 333) followed on July 4, 2026. This advisory outlines the enacted framework, eligibility criteria, and Turak Law's structured approach for Citizenship by Investment clients.
Advisory Notice
The 20-year foreign income tax exemption is in force under Mükerrer Article 20/D of Law No. 193, as added by Law No. 7582 and implemented by Tebliğ Seri No. 333 (Resmi Gazete No. 33300, July 4, 2026). Eligibility — in particular the prior three-year non-residency condition — is a fact-specific determination. This page constitutes general legal information only and does not constitute tax or legal advice specific to any individual's circumstances. Consult Av. Abdulsamed Burak Turak for a case-specific assessment. All information on this page is updated upon material regulatory developments.
Eligibility Framework
Who Qualifies — Announced Criteria
01Turkish Tax Residency Requirement
The exemption applies to individuals who establish Turkish tax residency under Article 3 of Law No. 193 (Gelir Vergisi Kanunu). Residency is established by residing in Turkey for more than six consecutive months in a calendar year, or by maintaining a permanent domicile (ikametgah) in Turkey.
02Foreign-Sourced Income Scope
Under Mükerrer Article 20/D of Law No. 193, the exemption covers foreign-sourced earnings and revenues — including dividends, capital gains, professional income, and rental income from foreign properties. Per Gelir Vergisi Genel Tebliği Seri No. 333 (Resmi Gazete No. 33300, July 4, 2026), exempt foreign income requires no Turkish tax return filing. Turkish-sourced income remains subject to standard taxation under the GVK.
03Interaction with Citizenship by Investment
Turkish citizenship obtained through the CBI program (Law No. 5901, Art. 12) does not automatically confer tax residency. Tax residency must be separately established. CBI clients who intend to relocate to Turkey or establish a Turkish domicile should engage Turak Law for a combined citizenship and tax residency analysis.
04Prior Non-Residency Condition
The exemption applies to real persons who had no residence or tax liability in Türkiye during the three calendar years preceding settlement, and is effective for persons settling in Türkiye from January 1, 2026. Whether an individual satisfies the prior non-residency condition is a fact-specific determination — Turak Law assesses this at consultation before any exemption planning.
Our Approach
Turak Law — Tax Residency Advisory Process
Eligibility Assessment
Consultation with Av. Abdulsamed Burak Turak to assess existing residency status, citizenship, and income structure against the published framework criteria.
Residency Establishment Roadmap
If Turkish tax residency is not yet established, Turak Law prepares a structured plan covering İkamet Tezkeresi (residence permit), domicile registration with Turkish civil authorities (Nüfus Müdürlüğü), and timeline coordination.
Implementation Monitoring
Turak Law tracks GİB rulings and further Tebliğ amendments on the application of Mükerrer Article 20/D. Clients are notified immediately of any change to the implementation framework.
Exemption Application
Turak Law coordinates the formal position with the Gelir İdaresi Başkanlığı (GİB — Revenue Administration) under Tebliğ Seri No. 333 procedures, including the prior non-residency documentation. All documentation prepared in Turkish and client language.
Related Service
Citizenship by Investment — The First Step
Turkish tax residency requires physical presence or a Turkish domicile — but Turkish citizenship is not a prerequisite. However, for investors seeking both a second citizenship and a favourable tax framework, the bank deposit or real estate CBI pathway provides a natural entry point. Turak Law manages both tracks as a unified legal mandate.
Tax Residency Advisory
Schedule a Consultation with
Av. Abdulsamed Burak Turak
Discuss your current tax residency, income structure, and citizenship status. Turak Law will prepare a case-specific analysis of the 20-year exemption framework and your eligibility pathway.
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