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Türkiye 20-Year Tax Exemption 2026: Foreign Residents Reset | NTL

Türkiye 20-year foreign income tax exemption 2026 legislative reform Grand National Assembly

🇹🇷 Legislative Update

Türkiye 20-Year Tax Exemption 2026: Foreign Residents Reset

Q: How does the Türkiye 20-year regime compare to Italy's Article 24-bis or Greece's Article 5A?

Italy under Article 24-bis TUIR imposes a flat EUR 200,000 substitute tax per year for up to 15 years. Greece under Article 5A of Law 4172/2013 imposes EUR 100,000 per year for up to 15 years with a EUR 500,000 investment commitment. The Türkiye regime, once gazetted, provides a 20-year horizon with no annual substitute tax on foreign-source income.

Q: Can clients begin preparation work before the law is published in the Resmî Gazete?

Yes, with caveats. Pre-publication preparation can include source-country tax position analysis, existing-structure review, banking coordination for the wealth amnesty, corporate structuring decisions, and estate planning revision. Formal declarations and Turkish transfer steps must wait until the law is gazetted and implementing regulations are issued.

20 Years

Foreign Income Exemption

Inheritance & Gift Tax

3 Years

Non-Residency Required

Jul 2027

Wealth Amnesty Deadline

By NTL International Published 25 May 2026 Category Tax Residency & Compliance Jurisdiction Türkiye

Key Takeaways

The Grand National Assembly of Türkiye (TBMM) accepted the tax reform package (Esas No: 2/3669, Sıra Sayısı: 270) on 21 May 2026; the law has not yet been published in the Resmi Gazete and is therefore not yet enforceable.
Once gazetted, qualifying foreign individuals who relocate to Türkiye will receive a 20-year exemption from Turkish income tax on foreign-sourced earnings, under a new Article 20/D (Mükerrer) inserted into Income Tax Law No. 193.
Inheritance and gift tax for those qualifying for the 20-year exemption will be reduced to a flat 1%, applied during the exemption period.
A wealth amnesty (Geçici Madde 19, Corporate Tax Law No. 5520) will allow declaration of foreign assets through 31 July 2027 at a standard 5% rate, with reduced rates of 0% to 4% available subject to specified conditions.
Eligibility requires that the individual was not resident in Türkiye for the three calendar years immediately preceding relocation.
The framework creates a unique layering opportunity for applicants to the Türkiye Citizenship by Investment programme who plan to establish tax residency after acquiring citizenship.

On 21 May 2026, the General Assembly of the Grand National Assembly of Türkiye accepted a comprehensive amendment to several Turkish tax laws. The legislation, registered under Esas No: 2/3669 and circulated as Sıra Sayısı 270, introduces three structural changes of strategic importance to international high-net-worth individuals: a 20-year exemption from Turkish income tax on foreign-sourced earnings, a reduced 1% inheritance and gift tax rate for the same population, and a wealth amnesty programme permitting the declaration of previously undeclared foreign assets through 31 July 2027.

This compliance brief sets out the legislative status, the statutory basis for each provision, the eligibility conditions, and the strategic implications for clients considering relocation, second citizenship, or asset repatriation. The brief is published from primary government sources only: the TBMM Genel Kurul Gündemi, the Plan and Budget Committee report (Sıra Sayısı 270), and the daily issues of the T.C. Resmî Gazete.

Regulatory Framework and Legislative Status

The tax reform package was submitted to the TBMM Presidency on 5 May 2026 by Members of Parliament including Burdur MP Mustafa Oğuz, Osmaniye MP Seydi Gülsoy, and 64 additional signatories from the AK Party parliamentary group. The proposal was referred to the Plan and Budget Committee as the lead commission, with the Industry, Trade, Energy, Natural Resources, Information and Technology Committee designated as the secondary commission.

The Plan and Budget Committee accepted the proposal on 6 May 2026. The committee report was distributed on 12 May 2026. The General Assembly began discussion of the bill as a "Basic Law" (Temel Kanun) under Article 91 of the Internal Regulation, with the bill structured into two parts (Articles 1 to 7 and Articles 8 to 15). The General Assembly accepted the bill on 21 May 2026.

As of the date of this brief, the law has not yet been transmitted to the President for promulgation or published in the Resmî Gazete. The published statutes in the Resmî Gazete issues 33260 (21 May), 33261 (22 May), 33262 (23 May), 33263 (24 May), and 33264 (25 May 2026) consist of Law No. 7579 (Land Registry Law amendments), Law No. 7580 (Somalia grant agreement ratification), and Law No. 7581 (OECD Istanbul Centre protocol). The tax reform law will receive its enactment number upon gazette publication.

The 20-Year Foreign Income Tax Exemption

The central provision of the package is the new Article 20/D (Mükerrer) inserted into Income Tax Law No. 193. The article exempts qualifying real persons who establish tax residency in Türkiye from Turkish income tax on their foreign-sourced earnings and revenues for a period of 20 years from the date residency is established.

This is among the longest-duration foreign income exemption regimes available in any jurisdiction with a substantive immigration pathway. Comparable preferential regimes in the European Union and Mediterranean markets operate on shorter horizons, materially altering the long-term planning calculus for clients considering Türkiye against alternatives.

Türkiye (new regime)

20 years Mükerrer Madde 20/D

Foreign-sourced earnings exempt from Turkish income tax for two decades from establishment of residency, subject to passage of Law 2/3669.

Italy

15 years Article 24-bis TUIR

Flat substitute tax of EUR 200,000 per year on foreign-source income; family members at EUR 25,000 each.

Greece

15 years Article 5A Law 4172/2013

Flat lump-sum tax of EUR 100,000 per year on foreign-source income; family members at EUR 20,000 each, with a EUR 500,000 investment commitment.

Portugal NHR (closed)

10 years Closed 2024

The original Non-Habitual Resident regime closed to new applicants. Replacement IFICI is narrower in scope.

Eligibility Conditions

To qualify under Mükerrer Madde 20/D, the applicant must satisfy three statutory conditions verified in the Plan and Budget Committee report and the bill text:

Condition	Requirement
Non-residency window	The individual must not have been considered a resident of Türkiye during the three calendar years immediately preceding the establishment of new residency.
No prior full tax liability	The individual must not have had full taxpayer status or general tax liability in Türkiye during that same three-year period.
Source of income	The exemption applies exclusively to foreign-sourced earnings and revenues. Domestically sourced Turkish income remains subject to standard Turkish taxation under the Income Tax Law.

Existing limited Turkish tax liability arising from real estate income, capital income, or capital gains earned in Türkiye prior to entering the new regime does NOT, on its own, disqualify the individual from claiming the exemption, per the committee report. This is a meaningful clarification for clients with prior portfolio investments in Türkiye.

The 1% Inheritance and Gift Tax Regime

The package amends Article 16 of Inheritance and Gift Tax Law No. 7338 to introduce a flat 1% rate applicable to inheritance and gift transfers where the deceased or transferor qualifies under Mükerrer Madde 20/D and the transfer occurs during the 20-year exemption period. The standard Turkish inheritance and gift tax schedule is progressive and ranges materially higher than 1%, so the new flat rate represents a significant intergenerational planning advantage for clients structuring multi-generational wealth transfer through Turkish tax residency.

The 1% rate is conditional. It is not a universal reduction of the Turkish inheritance and gift tax regime. It applies only to the population that has entered the 20-year foreign income exemption regime, and only during the period the exemption remains in effect. Clients planning legacy structures using this rate should ensure that the residency status remains continuous through the period in which the inheritance event is expected.

Wealth Amnesty Window: Geçici Madde 19

Article 10 of the bill adds a new Geçici Madde 19 (Temporary Article 19) to Corporate Tax Law No. 5520. The provision creates a time-limited window during which individuals and corporations may declare assets held abroad, including cash, foreign currency, gold, equity, bonds, and other securities, and transfer those assets to Türkiye without the source of funds being subject to subsequent tax inspection within the scope of the declared amounts.

The amnesty is structured around four operational pillars verified through the committee report and reported by KPMG Tax citing the bill text directly:

Operational Element	Detail
Declaration deadline	31 July 2027 (subject to potential presidential extension; if extended, the applicable rate increases by an additional 0.5 percentage points for declarations made after that date)
Transfer window	Declared assets must be transferred to Türkiye within two months of declaration
Standard rate	5% on declared amounts
Reduced rate band	0% to 4% available subject to specified conditions, reportedly including term-deposit commitments to qualifying Turkish financial instruments
Holding requirement	Declared assets must be recorded in a special fund account on the balance sheet and held for two years; early withdrawal triggers compliance consequences
Audit immunity	No tax inspection or assessment will be conducted on amounts within the declared scope; this immunity is bounded by the declared amount and does not extend to undisclosed funds
Loss treatment	Losses on disposal of declared assets cannot be deducted for income or corporate tax purposes; tax paid on declaration cannot be expensed or offset against other taxes

The amnesty is materially different from a tax-free repatriation. A tax is payable on declared amounts. The principal benefit is procedural certainty: declared funds are insulated from retrospective audit on origin, and the holding and disclosure architecture provides a defensible compliance trail for clients with assets held in jurisdictions where the original source documentation may be incomplete.

Note: Legal/admin fees not included. Documentary materials need translation and Apostille where they originate outside Türkiye.

Strategic Positioning for International HNWIs

Three competitive frames matter for clients evaluating this regime:

Versus the UAE

The United Arab Emirates operates a 9% federal corporate tax (effective 1 June 2023) on profits above AED 375,000, alongside zero personal income tax. The Türkiye regime preserves the personal income exemption for 20 years on foreign-sourced earnings; clients whose income mix is dominated by foreign earnings rather than corporate activity within Türkiye may find a longer planning horizon under the Turkish regime than under shorter-duration alternatives. Clients with active Turkish business operations remain subject to standard Turkish corporate tax.

Versus Italy and Greece

Both Italy (Article 24-bis TUIR) and Greece (Article 5A of Law 4172/2013) impose flat lump-sum substitute taxes on foreign-source income, set at EUR 200,000 and EUR 100,000 per year respectively. Both regimes operate on a 15-year maximum horizon. The Türkiye regime is a 20-year horizon with no annual substitute tax; this is structurally different and, for very high foreign income, may represent meaningful aggregate savings over the planning period.

Versus Portugal

The original Portuguese Non-Habitual Resident regime closed to new applicants in 2024. The replacement IFICI (Incentivized Tax Regime for Scientific Research and Innovation) is narrower in scope. Clients who were considering Portugal for tax residency before 2024 and were unable to enter under the original NHR have, in the Turkish regime, an alternative with a longer duration.

Layering Turkish Tax Residency With Turkish Citizenship

Türkiye operates an established Citizenship by Investment programme with multiple investment routes. The tax reform package does not amend the CBI programme; the CBI statutory framework remains as enacted. The strategic value of the new tax regime for CBI applicants lies in the layering opportunity: a foreign national may acquire Turkish citizenship through the CBI programme, and separately establish Turkish tax residency to claim the 20-year exemption under Mükerrer Madde 20/D, provided the three-year non-residency precondition is satisfied.

This layering creates a combined position that is currently unique among major CBI jurisdictions: a second citizenship with visa-free or visa-on-arrival access to a meaningful set of destinations, paired with a long-duration tax residency exemption on foreign income. The Caribbean CBI programmes (St. Kitts and Nevis, Dominica, Grenada, Saint Lucia, and Antigua and Barbuda) do not offer a 20-year foreign income tax exemption regime of comparable structure. The combination of acquired Turkish citizenship plus elective Turkish tax residency is, under the new framework, a single-jurisdiction outcome that previously required structuring across two separate jurisdictions.

For clients whose strategic objective includes building a multi-jurisdictional Plan B portfolio, the Türkiye opportunity is now a component to be assessed alongside Caribbean CBI options. See NTL's earlier analysis, Why Every Investor Needs a Plan B, for the broader portfolio framework.

What Remains Pending Before the Law Takes Effect

Three procedural steps remain before the regime is operational:

Presidential promulgation. Under Article 89 of the Constitution, the law must be sent to the President within fifteen days of acceptance. The President may sign and promulgate, or return the law to Parliament for reconsideration within fifteen days. Reconsideration requires a simple majority to override.
Publication in the Resmî Gazete. The law takes effect from the date of publication unless the law itself specifies a different effective date. Some provisions in the package, including certain export-related corporate provisions, are scheduled to apply from the 2027 fiscal year onward.
Implementing regulations. Detailed application procedures, declaration forms, and qualifying financial instrument lists for the wealth amnesty will be issued by the Ministry of Treasury and Finance via subsidiary regulation or general communiqué. NTL will track and publish these as they are released.

NTL is monitoring the daily Resmî Gazete and will update this article on the date of gazette publication with the enactment number and the operational effective dates.

Türkiye's new framework creates a layering opportunity that no other major citizenship by investment jurisdiction currently offers. A client who establishes Turkish tax residency after three years of demonstrated non-residency, and who has independently acquired Turkish citizenship through the established investment routes, will hold a single-jurisdiction structure combining mobility and a 20-year horizon on foreign income exemption. The compliance discipline still matters: the three-year non-residency precondition, the residency establishment process, and the wealth amnesty declaration mechanics must each be executed correctly. This is not a self-serve regime.

Imad Elbitar , Managing Partner, NTL International

Türkiye Tax Reform 2026 FAQ: Eligibility, Timing, and Strategy

Is the Türkiye 20-year foreign income tax exemption currently in force?

Not yet. The Grand National Assembly accepted the bill (Esas No: 2/3669) on 21 May 2026. The law has not been transmitted to the President or published in the Resmî Gazete as of the date of this brief. Under Article 89 of the Constitution, the law is enforceable only after presidential promulgation and publication in the Official Gazette. NTL will update this article on the gazetting date.

Who qualifies for the 20-year foreign income tax exemption in Türkiye?

Real persons who establish tax residency in Türkiye and who satisfy two preconditions: they were not considered residents of Türkiye for the three calendar years immediately preceding relocation, and they did not have full taxpayer status or general tax liability in Türkiye during that period. The exemption applies exclusively to foreign-sourced earnings; Turkish-sourced income remains subject to standard Turkish taxation.

Does the Türkiye Citizenship by Investment programme change under this legislation?

No. The CBI programme statutory framework is not amended by Law 2/3669. The strategic interaction is that Turkish citizens, including those who acquired citizenship through the CBI routes, may separately establish Turkish tax residency and claim the 20-year exemption provided the three-year non-residency precondition is satisfied.

What is the Türkiye wealth amnesty rate under Geçici Madde 19?

The standard rate is 5% on declared foreign assets. Reduced rates of 0% to 4% are available subject to specified conditions, including term-deposit commitments to qualifying Turkish financial instruments per primary source commentary. Declared assets must be transferred to Türkiye within two months of declaration and held for two years in a special fund account. The declaration deadline is 31 July 2027.

What is the inheritance and gift tax rate for qualifying foreign residents in Türkiye?

1% on inheritance and gift transfers where the transferor qualifies under Mükerrer Madde 20/D and the transfer occurs during the 20-year exemption period. The standard Turkish inheritance and gift tax schedule is progressive and substantially higher; the 1% rate is conditional on continued qualification under the foreign income exemption regime.

How does the Türkiye 20-year regime compare to Italy's Article 24-bis or Greece's Article 5A?

Italy's regime under Article 24-bis TUIR imposes a flat EUR 200,000 substitute tax per year for up to 15 years. Greece's regime under Article 5A of Law 4172/2013 imposes a flat EUR 100,000 lump sum per year for up to 15 years with a EUR 500,000 investment commitment. The Türkiye regime, once gazetted, provides a 20-year horizon with no annual substitute tax on foreign-source income, subject to the eligibility conditions described above.

Can clients begin preparation work before the law is published in the Resmî Gazete?

Yes, with caveats. Pre-publication preparation can include: source-country tax position analysis, existing-structure review, banking coordination for the wealth amnesty, corporate structuring decisions, and estate planning revision under the 1% inheritance regime. Formal declarations and Turkish transfer steps must wait until the law is gazetted and implementing regulations are issued.

About NTL International

NTL provides professional guidance and compliance support for global Citizenship by Investment and Residency by Investment programmes. As a government-authorized agent in select jurisdictions and collaborator with specialized legal experts worldwide, NTL manages the entire application process, ensuring every application meets statutory requirements from initial assessment through final approval, working with local counsel for full compliance.

NTL's compliance practice serves licensed advisors, family offices, and high-net-worth individuals seeking regulatory-grade analysis of cross-border immigration and nationality frameworks. The firm advises only on programmes with established legal foundations and verifiable processing standards.

For clients evaluating the Türkiye 20-year foreign income exemption, NTL coordinates the residency establishment process and the interaction with Turkish citizenship acquisition through the Türkiye CBI programme. Cross-border tax structuring is handled in collaboration with specialized tax counsel in the relevant jurisdictions, including the source country of the client's foreign income and any prior residency jurisdictions.

Official Sources

Grand National Assembly of Türkiye (TBMM) Genel Kurul Gündemi, 28th Legislative Period, 4th Legislative Year, recording the General Assembly session of 21 May 2026 and the Plan and Budget Committee report distributed under Sıra Sayısı 270 for Esas No: 2/3669. tbmm.gov.tr
TBMM Kanun Teklifi Bilgileri portal, official entry for the proposal Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun Teklifi (2/3669). tbmm.gov.tr Yasama
T.C. Resmî Gazete Official Portal, daily issues for 21 to 25 May 2026 (issues 33260 through 33264) confirming that the tax package has not yet been gazetted. resmigazete.gov.tr
Income Tax Law No. 193 (Gelir Vergisi Kanunu), referenced for the insertion of Mükerrer Madde 20/D.
Inheritance and Gift Tax Law No. 7338 (Veraset ve İntikal Vergisi Kanunu), referenced for the amendment to Article 16 establishing the 1% rate.
Corporate Tax Law No. 5520 (Kurumlar Vergisi Kanunu), referenced for the insertion of Geçici Madde 19 governing the wealth amnesty.
Constitution of the Republic of Türkiye, Article 89, governing the promulgation and publication of laws.

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