You are a Turkish tax resident if your domicile is in Turkey or if you stay in Turkey continuously for more than six months within a calendar year; temporary trips abroad do not interrupt the stay (Income Tax Law, Article 4). Foreigners who come for a specific temporary job, or for study, treatment, rest or travel, are not residents even after six months (Article 5). Residents are taxed on worldwide income, non-residents only on Turkish income.
Tax residency is the single question that decides whether Türkiye may tax only the income you earn within its borders or everything you earn anywhere in the world. It is an entirely separate question from your immigration status: a residence permit allows you to live in Türkiye, while tax residency follows the rules of the Income Tax Law, Law No. 193, and the two can point in opposite directions. Many foreigners arrive assuming that a 183 day rule applies, as it does in a large number of other countries. The Turkish rule is worded differently, the difference is not academic, and it matters most for exactly the people who tend to overlook it: retirees who split the year between two homes, remote workers, investors who obtained citizenship through the investment programme, and executives on extended assignments. This guide explains the two tests for tax residency, the statutory exceptions for foreigners, the consequences of resident and non-resident status, how double tax treaties resolve dual residence, and how to obtain the tax residency certificate that foreign authorities will ask for, all under the law as it stands following the 2026 tax package.
Quick Answer: Under Article 4 of the Income Tax Law, Law No. 193, you are a Turkish tax resident if your legal domicile is in Türkiye, or if you stay in Türkiye continuously for more than six months within a single calendar year, with temporary departures abroad not interrupting the stay. Either test alone is sufficient. Under Article 5, foreigners who come to Türkiye for a specific and temporary assignment, or for study, medical treatment, rest, or travel, are not treated as residents even if they stay longer than six months. Residents are subject to full tax liability on their worldwide income under Article 3; non-residents are subject to limited liability on Turkish source income only under Article 6. Where another country also treats you as resident, the tie breaker rules of the applicable double tax treaty decide, in a fixed order starting with the permanent home and the centre of vital interests. Since 2026, individuals who become Turkish tax residents after three years without Turkish domicile or liability may benefit from a 20 year exemption on foreign source income under Additional Article 20/D. The usual proof of Turkish residence abroad is the tax residency certificate, mukimlik belgesi, issued by the Revenue Administration through the Digital Tax Office.
Foreigners in Türkiye deal with two different authorities whose definitions of residence have nothing to do with each other. The Directorate General of Migration Management issues residence permits under the Law on Foreigners and International Protection, Law No. 6458, and asks whether you may lawfully remain in the country. The Revenue Administration applies the Income Tax Law and asks whether you are settled in Türkiye for tax purposes. A person may hold a short term residence permit renewed every year and be a tax resident from the first day because his or her domicile has moved; another may hold a long term permit and never become a tax resident because his or her life remains centred abroad and the stays in Türkiye are short.
The financial difference between the two statuses can be very large. A tax resident must, in principle, declare foreign pensions, foreign dividends and interest, foreign rental income, and gains on foreign shares in a Turkish annual return, and will pay Turkish tax on them at progressive rates subject to treaty relief and the exemptions discussed in section 6. A non-resident declares nothing of the kind. Getting the status right, and being able to prove it, is therefore the starting point of any sensible tax position for a foreigner with ties to Türkiye.
Article 3 of the Income Tax Law provides that real persons settled in Türkiye are taxed on all of their income, whether earned inside or outside Türkiye. Article 4 then defines who is settled, yerleşmiş, and sets out two independent tests. Satisfying either one is enough.
The first test is that the person's domicile, ikametgah, is in Türkiye. Article 4 refers expressly to the meaning of domicile under the Turkish Civil Code, Law No. 4721, whose Article 19 defines it as the place where a person lives with the intention of staying permanently. The test is therefore partly factual and partly intentional: it asks where the person's home actually is and whether the person intends it to be a permanent home rather than a temporary base. Registration of an address in the Turkish address registration system, MERNİS, through the population directorate is strong evidence of domicile, but the tax authority may also look at where the family lives, where the person's economic interests are concentrated, and whether a home abroad has been given up.
The consequence of the domicile test is that a foreigner who moves to Türkiye with the intention of living here permanently is a tax resident from the date of the move. There is no need to wait for six months to pass, and the first calendar year of residence is a year of full liability from the date of arrival, not from the day the six month threshold is crossed.
The second test is that the person stays in Türkiye continuously for more than six months within one calendar year. Article 4 adds that temporary departures do not interrupt the period of stay. This test applies regardless of intention: a person who has no wish to settle, and who maintains a home and family abroad, becomes a Turkish tax resident for the year in question if the stay exceeds six months, unless one of the exceptions in Article 5 applies.
The second test is routinely described, including by many advisers abroad, as the 183 day rule. That is not how the statutory text reads, and the differences produce different outcomes in the situations that matter most to foreigners who divide their time between countries.
The Turkish test looks at a continuous stay of more than six months within one calendar year, running from 1 January to 31 December. It is not a rolling twelve month test, and it is not a test of total days present over any period. A stay that straddles two calendar years, for example from late September to late April, may fall short of six months in each year taken separately, in which case the stay test is not met in either year even though the person was physically present for seven consecutive months.
Because the law expressly states that temporary departures do not interrupt the period of stay, short trips abroad during an otherwise continuous presence in Türkiye are ignored for the purpose of the test. A foreigner who arrives in February, leaves for two weeks in May and again for ten days in July, and departs in October has stayed continuously for more than six months within the meaning of Article 4, even though a strict count of days physically present might fall below 183. The law does not define how long an absence may be before it ceases to be temporary; the assessment turns on whether the person's stay in Türkiye continued in substance through the absence, which is a question of fact.
The 183 day figure that appears in most double tax treaties concluded by Türkiye relates to a different question altogether. Article 15 of the OECD Model Convention, on which most Turkish treaties are based, allows the country where an employee works to tax the salary if the employee is present there for more than 183 days in the relevant period, among other conditions. That rule allocates taxing rights over employment income between two countries; it does not define residence under Turkish domestic law and does not replace the Article 4 test. Confusing the two leads foreigners to believe that they are safe at 180 days in Türkiye, when the domestic test may already have been met through a continuous stay or through domicile.
Article 5 of the Income Tax Law excludes certain foreigners from the stay test even where their presence in Türkiye exceeds six months in a calendar year. The exclusion applies to foreigners only, and it depends on the purpose of the stay rather than on the type of permit held.
| Category Under Article 5 | Typical Examples |
|---|---|
| A specific and temporary assignment or business | Business people, scientists, experts, officials, press and broadcasting correspondents, and similar persons who come for a defined temporary job or task |
| Study, medical treatment, rest, or travel | Students, patients receiving treatment, retirees on an extended stay for rest, and tourists |
| Circumstances beyond the person's control | Persons detained, convicted, or kept in Türkiye by illness and therefore unable to leave |
Two points about these exceptions are frequently misunderstood. First, they displace only the six month stay test, not the domicile test. A foreigner whose stay began as medical treatment or rest, but who has in fact moved his or her home, family, and business to Türkiye, can still be a resident through domicile under Article 4. Second, the exceptions are assessed by reference to the real purpose of the stay. A foreigner holding a tourism residence permit who works remotely from Türkiye for most of the year is not on a stay for rest or travel in substance, and the Revenue Administration is entitled to look past the permit category to the facts.
The Income Tax Law distinguishes between full liability, tam mükellefiyet, which attaches to residents under Article 3, and limited liability, dar mükellefiyet, which attaches to non-residents under Article 6. The table below sets out the practical consequences.
| Element | Tax Resident, Full Liability | Non-Resident, Limited Liability |
|---|---|---|
| Scope of taxable income | Worldwide income under Article 3 | Only income earned in Türkiye under Articles 6 and 7 |
| Rental income from Turkish property | Taxable, declared annually | Taxable; declared annually unless fully taxed by withholding |
| Foreign salary, pensions, dividends, interest | Taxable, subject to treaty relief and domestic exemptions | Not taxable in Türkiye |
| Capital gains on foreign assets | Taxable, subject to treaty relief and domestic exemptions | Not taxable in Türkiye |
| Foreign tax credit | Available under Article 123 for foreign tax paid on foreign income | Not relevant |
| Annual return | Required where income exceeds the declaration thresholds | Required only for Turkish income not fully taxed at source |
Article 7 of the Income Tax Law sets out when income is regarded as earned in Türkiye for a non-resident: broadly, where the business is carried on through a permanent establishment or representative in Türkiye, where the employment is performed in Türkiye, where the immovable property is located in Türkiye, where the capital is invested in Türkiye, and where the transaction giving rise to a gain is carried out in Türkiye. A non-resident who owns a Turkish apartment and lets it therefore pays Turkish tax on the rent, but pays no Turkish tax on a pension received from abroad.
The 2026 tax package introduced Additional Article 20/D into the Income Tax Law, creating a regime specifically aimed at individuals who move their tax residence to Türkiye. In outline, a real person who becomes a Turkish tax resident, and who had neither a domicile in Türkiye nor full income tax liability in Türkiye in the three calendar years preceding the move, may elect to have his or her foreign source income exempted from Turkish income tax for a period of 20 years. The exemption covers income arising outside Türkiye; Turkish source income remains taxable in the ordinary way.
Because the regime depends on the exact date on which residence begins, on the three year look back, and on the election being made within the prescribed period, the timing of a move to Türkiye has become a matter of real financial consequence. A person who inadvertently became a resident through a long stay in an earlier year may find that the look back test is failed. See our guide to the 20 year foreign income exemption and the overview of the 2026 tax package for the conditions in detail.
It is common for two countries to treat the same person as resident at the same time: Türkiye through a stay of more than six months, and the home country through a permanent home, continued registration, or its own day count. Türkiye has double tax treaties in force with more than 85 countries, and the great majority follow the OECD Model Convention. Under Article 4 of the Model, where both states regard an individual as resident under their domestic law, the treaty assigns residence to one of them by a fixed sequence of tie breaker rules.
The tests are applied in order, and the first test that produces a clear answer is decisive. First, the individual is resident in the state where he or she has a permanent home available; if a permanent home is available in both states, residence goes to the state with which the personal and economic relations are closer, the centre of vital interests. If that cannot be determined, or if there is no permanent home in either state, the individual is resident where he or she has an habitual abode. If there is an habitual abode in both or neither, nationality decides. If the individual is a national of both or neither, the competent authorities of the two states settle the question by mutual agreement.
Although the structure is standard, the wording, the definitions, and the allocation rules for particular types of income differ from treaty to treaty, and some older Turkish treaties depart from the Model in material respects. The treaty that applies is the one between Türkiye and the other state claiming residence, and its text, together with any protocol, should always be read before a position is taken. Our guide to the Türkiye and United States treaty illustrates how one such treaty operates in practice.
Where the treaty assigns residence to the other state, Türkiye taxes the individual as a non-resident for treaty purposes, but the domestic classification under Article 4 does not disappear. The individual may still have to file in Türkiye, claim the treaty position in the return, and be prepared to document it with a residency certificate from the other state. Treaty relief is claimed, not presumed.
To claim treaty benefits abroad, for example a reduced withholding tax on dividends or interest paid from another country, or to demonstrate to a former home country that tax residence has moved, foreign tax authorities will usually require a Turkish tax residency certificate, mukimlik belgesi. The certificate confirms that the Revenue Administration regards the person as a resident of Türkiye for the purposes of the relevant treaty in the year concerned.
Applications are made electronically through the Revenue Administration's Digital Tax Office, Dijital Vergi Dairesi, or through the e-Devlet portal, using the applicant's Turkish tax identification number. For foreign nationals, the certificate is issued centrally by the Revenue Administration rather than by the local tax office. The application identifies the treaty partner country and the tax year, and should be supported by evidence of residence such as entry and exit records, the address registration, and, where relevant, the residence permit. A foreigner who does not yet have one must first obtain a Turkish tax identification number, which can be done online with a passport.
The certificate is evidence of the Turkish authority's view; it does not bind the foreign authority, which applies its own domestic law and the treaty tie breaker independently. A person who holds a Turkish certificate but retains a permanent home and family abroad may still be treated as resident there until the tie breaker is worked through. Conversely, the absence of a certificate does not mean a person is not a Turkish resident under Article 4.
A small number of measures taken before and shortly after a move prevent most of the disputes and missed opportunities seen in practice. Keep a complete record of entry and exit dates for each calendar year, since the stay test is assessed year by year and the burden of proving absences falls in practice on the taxpayer. Decide deliberately whether and when you are moving your domicile, because under the domicile test the date of the move can determine residence more precisely than any day count, and because that date is the starting point for the 20 year exemption look back. Check whether your previous home country will continue to regard you as resident under its own law, and work through the treaty tie breaker before, not after, the first return is due in either country. If you may qualify for the exemption under Additional Article 20/D, confirm the three year look back test before you move rather than after, since an earlier year of inadvertent residence cannot be undone. Finally, keep the Turkish filing calendar in view from the first year of residence; our calendar of tax deadlines sets out the dates that apply to foreigners.
Not in that form. Under Article 4 of the Income Tax Law you are resident if your domicile is in Türkiye or if you stay continuously for more than six months within a calendar year, and temporary trips abroad do not interrupt the stay.
Not automatically. A residence permit is an immigration document issued under Law No. 6458. Tax residency depends on your domicile and on how long you actually stay in a calendar year.
Yes. The Income Tax Law looks at domicile and length of stay, not at immigration status; a person present unlawfully or on successive visa free entries can still satisfy Article 4.
Yes. Residents are subject to full liability on worldwide income under Article 3, subject to double tax treaty relief, the foreign tax credit in Article 123, and, for qualifying new residents, the 20 year foreign income exemption introduced in 2026.
Under Article 5, foreigners who come for a specific temporary assignment, or for study, medical treatment, rest, or travel, and persons kept in Türkiye by detention or illness. These exceptions do not override residence through domicile.
Not under the stay test, because the count runs within each calendar year separately and the stay may not exceed six months in either year. It may still make you resident if your domicile has moved.
No. Article 4 states expressly that temporary departures do not interrupt the period of stay, so short trips during an otherwise continuous presence are ignored.
The tie breaker rules of the applicable double tax treaty decide, in order: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the two tax authorities.
Apply electronically through the Revenue Administration's Digital Tax Office or e-Devlet with your Turkish tax identification number. Certificates for foreign nationals are issued by the Revenue Administration.
Yes. A Turkish tax identification number is required for the application and can be obtained online by a foreigner using a passport.
Yes. Rental income from immovable property located in Türkiye is Turkish source income under Article 7 and is taxable for residents and non-residents alike.
No. A foreign pension is not Turkish source income, so a non-resident pays no Turkish tax on it. A resident must declare it, subject to treaty relief and any applicable exemption.
A regime under Additional Article 20/D, introduced in 2026, allowing individuals who become Turkish tax residents after three years without Turkish domicile or liability to exempt their foreign source income from Turkish tax for 20 years.
No. Nationality is not a residence test under Article 4. A new citizen who continues to live abroad and stays less than six months in Türkiye remains a non-resident, although nationality can be relevant as a treaty tie breaker.
From the date of the move. The domicile test does not require six months to pass, and the first year is a year of full liability from the date of arrival.
Only if neither test is met in that year: your domicile must no longer be in Türkiye and your continuous stay must not exceed six months. Keeping a permanent home and family in Türkiye will usually preserve residence through domicile regardless of the day count.
Turkish tax residency rests on two tests in Article 4 of the Income Tax Law that are easy to state and easy to misapply: domicile in Türkiye, or a continuous stay of more than six months within a calendar year, with temporary absences disregarded. Neither test is a 183 day count, neither depends on the residence permit, and either alone brings full liability on worldwide income. The exceptions in Article 5 protect foreigners on genuinely temporary assignments or stays for study, treatment, rest, or travel, but not those whose home has in substance moved. Where two countries claim the same person, the treaty tie breaker decides, and the tax residency certificate is the document that makes the Turkish position usable abroad. Since 2026, the timing of a move has carried an additional consequence through the 20 year foreign income exemption, which rewards those who plan the date of residence and penalises those who drift into it.
We assess residence status before and after a move, apply for tax residency certificates, advise on treaty positions, and handle filings with the Turkish tax authorities. See our tax law service for the full scope of this work. For an assessment of your own position, or to plan the timing of a move with the 20 year exemption in mind, our legal team can review your circumstances and set out the steps required under the current law.
