Enacted Law — No. 7582 · In Force
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.
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 Attorney Abdulsamed Burak Turak for a case-specific assessment. All information on this page is updated upon material regulatory developments.
Eligibility Framework
Who Qualifies — Eligibility Criteria
Turkish 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 Türkiye for more than six consecutive months in a calendar year, or by maintaining a permanent domicile (ikametgah) in Türkiye.
Foreign-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.
Interaction 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 Türkiye or establish a Turkish domicile should engage Turak Law for a combined citizenship and tax residency analysis.
Prior 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.
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 Turkish 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 Attorney 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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