Under Mükerrer Article 20/D of the Income Tax Law, Law No. 193, added by Law No. 7582 (Official Gazette 4 June 2026, No. 33270), individuals who settle in Türkiye on or after 1 January 2026 pay no Turkish income tax on income earned abroad for 20 years, if they had no Turkish domicile or tax liability in the three prior calendar years. They must obtain an exemption certificate from their tax office by the end of the year of settlement, or by end February for November and December arrivals. Turkish income stays taxable.
Since 4 June 2026, Türkiye has had a statutory 20 year income tax exemption for people who move their tax residence to the country. The rule sits in Mükerrer Article 20/D of the Income Tax Law, Law No. 193, and it is no longer a proposal: the law is in force, the implementing communiqué has been issued, the Revenue Administration has published a guide, and the first tax office ruling on residence has been reported. The exemption is generous but narrow. It covers only income earned outside Türkiye, it is open only to people who settled in Türkiye on or after 1 January 2026 after three clean calendar years, and it is lost for good if the application misses a fixed deadline. This guide explains who qualifies, how residence and the source of income are determined, how to apply, and how the exemption interacts with tax treaties, citizenship and inheritance tax.
The word mükerrer, meaning "repeated", is the numbering device Turkish legislation uses for inserted articles. Article 20/D states that individuals deemed settled in Türkiye are exempt from income tax for twenty years on earnings and income derived outside Türkiye, provided they had neither a domicile nor a tax liability in Türkiye in the last three calendar years before settling. It adds that no annual return is filed for the exempt income, that related expenses cannot be deducted from taxable income, that foreign taxes paid on it cannot be credited, and that tax not assessed is treated as tax lost if the conditions later prove to be unmet.
Article 20/D was added by Article 4 of Law No. 7582 on Amendments to Certain Laws, dated 21 May 2026 and published in the Official Gazette of 4 June 2026, No. 33270. It entered into force on publication and applies to persons deemed settled in Türkiye from 1 January 2026. The procedure is set out in Income Tax General Communiqué Serial No. 333 (Official Gazette of 4 July 2026, No. 33300), and in September 2026 the Revenue Administration (Gelir İdaresi Başkanlığı, GİB) published a guide and an infographic based on it. Law No. 7582 also introduced the asset amnesty and other measures, covered in our guide to the 2026 Turkish tax package; this article deals only with Article 20/D.
The exemption is for individuals only; Article 3(10) of Communiqué No. 333 excludes corporate taxpayers. Nationality is irrelevant, so foreign nationals, dual nationals and Turkish citizens returning after years abroad are treated alike. The Communiqué adds that the person must have become settled in Türkiye on or after 1 January 2026, so an expatriate already resident in 2025 cannot use it, and must still be settled in Türkiye on the date of the application.
The test covers the three full calendar years before the year of settlement: for a person settled in 2026, these are 2023, 2024 and 2025. Both conditions below must be met for each year.
The person must not have had an ikametgâh, a domicile, in Türkiye. In the Communiqué's example, a person domiciled in Türkiye in 2022 who left on 10 November 2024 and returned in 2027 is refused, because he was still domiciled in Türkiye for part of 2024.
The person must also have had no tax liability in Türkiye, including liability as a non resident. The Communiqué refuses a person who earned wages in Türkiye from a single employer, taxed only by withholding, in one of the three years, and a person registered for business income. The second paragraph of Article 20/D makes three exceptions: a prior liability arising only from rent on Turkish property, income from Turkish securities or capital gains in Türkiye does not prevent the exemption.
| Situation in the three prior years | Effect on Article 20/D |
|---|---|
| Domicile in Türkiye at any time | Disqualifies |
| Wages earned in Türkiye, even if fully withheld | Disqualifies |
| Business or professional income in Türkiye | Disqualifies, even if established later in an audit |
| Rent from property in Türkiye | No obstacle |
| Dividends or interest from Türkiye | No obstacle |
| Capital gains in Türkiye, such as a property sale | No obstacle |
Article 20/D relies on the general rules of Law No. 193: a person settled in Türkiye has tam mükellefiyet, full tax liability on worldwide income (Article 3), while others are taxed only on Turkish income (Article 6). Our guide to tax residency in Türkiye explains these rules more broadly.
Under Article 4, a person is settled in Türkiye if his domicile is there or if he stays continuously for more than six months in one calendar year, temporary departures not interrupting the stay. Domicile is defined in Article 19 of the Turkish Civil Code, Law No. 4721, as the place where a person resides with the intention of settling permanently. A person who moves with his family and closes his life abroad is usually settled from the date of the move. Someone who arrives in August without that intention may only become settled the following year under the six month rule, which shifts both the deadline and the three test years.
Article 5 provides that certain foreigners are not settled even after six months: those who come for a specific and temporary assignment, for study, medical treatment, rest or travel, or who are held in Türkiye by detention or illness. The text refers to foreigners only, so a Turkish citizen, including a dual national, cannot rely on it.
In a ruling (özelge) dated 13 October 2026, as reported in the tax press, the Istanbul Tax Office Directorate declined to accept an applicant's declared settlement date as such and required it to be established from documents. It also held that a Turkish address registration alone does not defeat the domicile condition where the person proves with a foreign residence or work permit that he actually lived abroad, provided he documents a permanent return on or after 1 January 2026. A ruling binds the office only for the applicant, but it shows the approach.
Only income earned outside Türkiye is exempt; Article 3(7) of the Communiqué confirms that Turkish income remains taxable. Article 7 of Law No. 193 sets out when income is earned in Türkiye, and income that does not meet those tests is foreign. Wages and professional fees are earned in Türkiye if the work is performed there or paid or charged to a payer there; rent if the property is in Türkiye; interest and dividends if the capital is invested in Türkiye; business income if there is a Turkish workplace or permanent representative.
For services, the place of performance decides. The Communiqué's own example is an engineer in Türkiye advising foreign clients on their Turkish investments: his fees are Turkish income. A person who works from a laptop in Bodrum for a London employer is in the same position, which remote workers considering the digital nomad visa should note.
| Income | Treatment under Article 20/D |
|---|---|
| Rent from a flat in Germany | Exempt |
| Rent from a flat in Istanbul | Taxable in Türkiye |
| Dividends from a foreign company | Exempt |
| Interest on a deposit held abroad | Exempt |
| Interest on money transferred to a Turkish bank | Taxable in Türkiye |
| Fees for work performed and paid abroad | Generally exempt |
| Fees or salary for work done in Türkiye for foreign clients or employers | Taxable in Türkiye |
Two further points matter. Money brought into Türkiye earns Turkish income from then on. And under Article 3 of the Corporate Tax Law, Law No. 5520, a foreign company whose iş merkezi, its place of effective management, is in Türkiye becomes a Turkish full taxpayer, so managing a foreign company from Türkiye can turn its profits and dividends into Turkish income.
The exemption is not automatic. Article 3(4) of the Communiqué requires an application to the tax office competent to assess the person's income tax for the "Exemption Certificate for Earnings and Income Derived from Abroad" in the form of its Annex 1. Under Article 4, the office checks that the applicant is settled in Türkiye, had no domicile or tax liability in the three prior years, and applied in time.
The application must be filed by the end of the calendar year of settlement, or, for those settled in the last two months of the year, by the end of February of the following year.
| Settlement date | Application deadline |
|---|---|
| 1 January to 31 October 2026 | 31 December 2026 |
| 1 November to 31 December 2026 | 28 February 2027 |
| 1 January to 31 October 2027 | 31 December 2027 |
| 1 November to 31 December 2027 | 29 February 2028 |
In the Communiqué's example, a person who settled on 2 March 2028 and applied on 1 May 2030 met every other condition but was refused. A late application cannot be cured.
The Communiqué does not list documents, and offices may differ. We recommend a file proving both the settlement date and the three clean years: passport, residence permit and a Turkish tax identification number; a lease or title deed and address registration; entry and exit records; foreign residence or work permits, tax residence certificates and tax returns for the three test years; and a list of the foreign income sources. Our tax law team prepares the file and petition and follows it up with the tax office.
Exempt foreign income is not declared. Turkish income, such as rent from an Istanbul flat, is still declared in March where the normal rules require a return, and the foreign income is left out of that return. Expenses linked to exempt income cannot be deducted, and Article 88 of Law No. 193 bars setting foreign losses relating to exempt income against Turkish income. The usual foreign tax credit of Article 123 is excluded, so tax withheld abroad, for example on foreign dividends, is a final cost.
Records matter for all 20 years. The Tax Procedure Law, Law No. 213, allows an assessment within five years from the start of the year after the tax arose (Article 114), and an audit may ask why transfers arrived in a Turkish account. Keep bank statements, foreign tax documents, leases, dividend vouchers and contracts showing where services were performed, and hold foreign income in separate accounts where possible.
Article 20/D does not bind the source country or the country the person has left. Under Article 90 of the Constitution, treaties duly put into effect have the force of law, and Türkiye's network is described in our article on double taxation agreements in Türkiye. Since foreign tax cannot be credited, it is worth claiming reduced treaty rates at source, usually with a Turkish mukimlik belgesi, a certificate of residence. Some treaties restrict relief where income is not taxed in the residence state, and the former country may still treat the person as resident under its own law; the treaty tie breaker rules then decide. Leaving the former country properly is as important as arriving.
Holding Turkish citizenship by investment under Article 12 of the Turkish Citizenship Law, Law No. 5901, does not make anyone settled in Türkiye. An investor with a Turkish passport who lives in Dubai remains outside Turkish tax on foreign income and does not need Article 20/D. Citizenship does not bar the exemption either: a new citizen who later moves can qualify. But a new citizen loses the Article 5 exceptions in section 4.2, and citizenship can bring property abroad within Turkish inheritance tax. A residence permit under Law No. 6458 is likewise an immigration status, although useful evidence of the settlement date.
Law No. 7582 added a paragraph to Article 16 of the Inheritance and Transfer Tax Law, Law No. 7338: for persons benefiting from Article 20/D, transfers by inheritance within the exemption period are taxed at 1%, instead of the inheritance scale of 1% to 10%. The reduced rate is not limited to foreign assets, and it does not cover gifts, which remain at the normal rates. The text does not say expressly whether it also covers inheritances the beneficiary receives from others.
Under Article 1 of Law No. 7338, the tax reaches property in Türkiye, property of Turkish citizens and property Turkish citizens acquire abroad. For a foreign national with assets abroad, Turkish inheritance tax may not arise at all; for Turkish citizens and property in Türkiye, the 1% rate matters. Our inheritance law team reviews the succession and tax sides together.
If the conditions prove to be unmet, Article 5 of the Communiqué provides that the tax is collected with a vergi ziyaı cezası, a tax loss penalty, and late payment interest, and the GİB guide adds that the certificate is cancelled. Under Article 344 of Law No. 213, the penalty normally equals the tax lost and is tripled for the fraudulent acts in Article 359. In the Communiqué's example, a certificate issued on 1 December 2026 was cancelled from the settlement date after an audit found unregistered business in Türkiye in 2025.
The usual causes are an unprovable settlement date, a forgotten Turkish job or contract in the test years, treating work done in Türkiye as foreign because the client is abroad, and managing a foreign company from Türkiye. Under Article 6 of the Communiqué, a person who stops being resident is taxed under the general rules, which do not reach foreign income. Whether the 20 years are extended for time spent abroad is not addressed.
Anna moves to Istanbul with her family in March 2026 and had no Turkish domicile or income in 2023 to 2025. She applies in October 2026. Rent from her Munich flat and dividends on US shares held with a German broker are exempt; interest on euros she moved to a Turkish bank is taxed by withholding.
David settles in Antalya in 2026 and keeps serving London clients, who pay into his UK account. He obtains the certificate, but his fees are Turkish income because he works in Türkiye. Only his Manchester rent and UK savings interest are exempt.
Mehmet has lived in the Netherlands on a Dutch permit since 2019 but kept his Turkish address registration. He returns permanently on 15 November 2026, so his deadline is 28 February 2027. Following the October 2026 ruling, the registration is not in itself an obstacle if he documents life abroad in 2023 to 2025. Had he worked for a Turkish employer in 2024, he would not qualify.
It is the exemption in Mükerrer Article 20/D of Law No. 193 for individuals who settle in Türkiye from 1 January 2026. Their income earned abroad is exempt for 20 years if they had no Turkish domicile or tax liability in the three prior calendar years.
No, any individual can qualify, including returning Turkish citizens. Companies cannot.
No, because you were settled before 1 January 2026 and were domiciled in Türkiye in the test years.
No, prior liability for rent, securities income or capital gains in Türkiye is expressly allowed. Wages or business income in Türkiye in the test years does disqualify.
The end of the calendar year in which you settled, or the end of February of the next year if you settled in November or December. Missing it means no exemption.
To the tax office competent to assess your income tax, which issues the exemption certificate annexed to Communiqué No. 333 after checking the conditions.
No, exempt foreign income is not declared, even if you file a return for Turkish income.
No, if you do the work in Türkiye, because wages and fees are earned where the work is performed.
No, interest on capital invested in Türkiye is Turkish income.
No, Article 20/D excludes the credit, so reduced treaty rates at source are worth claiming.
No, residence depends on domicile or a stay of more than six months in a calendar year, not on nationality.
For persons benefiting from Article 20/D, transfers by inheritance within the exemption period are taxed at 1% under Article 16 of Law No. 7338. Gifts are taxed at the normal rates.
The certificate is cancelled and the tax is collected with a tax loss penalty, normally equal to the tax, and late payment interest.
Mükerrer Article 20/D of Law No. 193, added by Law No. 7582 and implemented by Communiqué No. 333, exempts foreign income from Turkish income tax for 20 years for individuals of any nationality who settle in Türkiye from 1 January 2026 after three calendar years without a Turkish domicile or tax liability, other than for rent, securities income or capital gains. It requires a certificate applied for by the end of the year of settlement, or by the end of February for November and December arrivals, covers only income earned abroad, excludes foreign tax credits, and brings a 1% inheritance tax rate during the exemption period.
Because the deadline cannot be extended and the settlement date, the test years and the source of each income stream must all be proven, the time to prepare is before the move. If you plan to settle in Türkiye and want your eligibility and application reviewed, you can contact our legal team.
