20-Year Foreign Income Exemption for New Residents of Türkiye

Yes, such an exemption is in force. Law No. 7582 added Article 20/D (a “mükerrer” or supplementary article) to the Income Tax Law (Gelir Vergisi Kanunu, GVK). Under it, individuals who are deemed resident in Türkiye (Türkiye’de yerleşmiş sayılan) from 1 January 2026 onwards, and who had neither a domicile (ikametgâh) nor a tax liability (vergi mükellefiyeti) in Türkiye in the last three calendar years before that, are exempt from income tax on their earnings and income derived outside Türkiye (kazanç ve iratlar) for twenty years (GVK mük. m. 20/D-1; 7582 s. Kanun m. 4 and m. 14/a). The three-calendar-year condition has one exception: a tax liability in Türkiye during that period arising solely from income from immovable property (e.g. rent), income from movable capital or capital gains is not an obstacle (GVK mük. m. 20/D-2). To benefit from the exemption, you must apply to the tax office in time and obtain an exemption certificate (istisna belgesi). Income from Turkish sources continues to be taxed as usual. Receiving payment from a client abroad does not by itself determine the source of the income: a fee for a service performed in Türkiye is not covered by the exemption even if it is paid by a foreign client (333 Seri No.lu GVGT m. 3, Example 10).

Legal Basis and Entry into Force

The provision was introduced by Article 4 of Law No. 7582 on Amendments to Certain Laws (7582 sayılı Bazı Kanunlarda Değişiklik Yapılmasına Dair Kanun) dated 21 May 2026. The Law was published in Official Gazette (Resmî Gazete) No. 33270 of 4 June 2026. Under the entry-into-force article, Article 4 took effect on the date of publication. However, it applies to persons deemed resident in Türkiye from 1 January 2026 onwards (7582 s. Kanun m. 14/a). Persons who settled in Türkiye in 2025 or earlier therefore cannot benefit from this exemption.

The implementing procedures and principles were set out in the General Communiqué on Income Tax (Gelir Vergisi Genel Tebliği, GVGT) Serial No. 333, published in Official Gazette No. 33300 of 4 July 2026. The Communiqué also took effect on the date of publication (333 Seri No.lu GVGT m. 7). Law No. 7582 did not add a transitional article (geçici madde) to the GVK for this exemption; the only transitional article added by the Law is provisional Article 19 of Corporate Tax Law No. 5520 (7582 s. Kanun m. 10). The timing of the exemption is tied to the date of 1 January 2026 in the entry-into-force article (m. 14/a).

Who Can Benefit

Only individuals can benefit from the exemption. Companies subject to corporate tax (kurumlar vergisi mükellefi) are outside its scope (333 Seri No.lu GVGT m. 3). The conditions are as follows:

• Being deemed resident in Türkiye. The person must be resident in Türkiye as of the application date (333 Seri No.lu GVGT m. 3/2).
• A settlement date of 1 January 2026 or later (7582 s. Kanun m. 14/a; 333 Seri No.lu GVGT m. 3/3).
• The three-calendar-year look-back condition. In the last three calendar years before becoming resident in Türkiye, the person must have had neither a domicile nor a tax liability in Türkiye (GVK mük. m. 20/D-1). For example, for a person who settles in 2026, the years examined are 2023, 2024 and 2025.
• Timely application and the exemption certificate. The exemption does not apply automatically. A certificate must be obtained (see below).

Which Prior Tax Liabilities Are Not an Obstacle

The Law does not treat it as an obstacle if, during the three-year period, the person was liable to tax in Türkiye solely because of income from immovable property (gayrimenkul sermaye iradı, e.g. rent), income from movable capital (menkul sermaye iradı, e.g. dividends, interest) or capital gains (değer artışı kazancı) (GVK mük. m. 20/D-2; 333 Seri No.lu GVGT m. 3/5). The Communiqué illustrates that a person who declared rental income in Türkiye before settling is not prevented from obtaining the certificate (333 Seri No.lu GVGT m. 3, Example 5). These three income types are the only exceptions listed in the text of the Law. The examples in the Communiqué show that no certificate is issued where, during this period, the person had employment income (ücret geliri), business income (ticari kazanç) or unregistered business activity (kayıt dışı ticari faaliyet) in Türkiye (333 Seri No.lu GVGT m. 3, Examples 6, 7 and 12). Self-employment income (serbest meslek kazancı) and agricultural income (zirai kazanç) are not illustrated separately in the Communiqué. However, since they fall outside the exceptions listed in the Law, a tax liability arising from these types of income should also be considered an obstacle.

An activity started in Türkiye after settling does not affect the look-back condition. In one example in the Communiqué, a certificate is issued to a person who started retail trading a few months after settling (333 Seri No.lu GVGT m. 3, Example 3). For a person who previously lived in Türkiye, left and then returned, however, the condition is not met if the year of departure falls within the three-year period (same article, Example 4).

Relationship with the Rules on Residence in Türkiye

The starting point of the exemption is “being deemed resident in Türkiye” (Türkiye’de yerleşmiş sayılma). This concept rests on the general provisions of the GVK. Under GVK Art. 4, persons whose domicile is in Türkiye, and persons who stay in Türkiye continuously for more than six months within a calendar year, are deemed resident in Türkiye. Temporary departures do not interrupt this period. Under GVK Art. 5, however, foreigners who come for a specific and temporary assignment or job, or for study, medical treatment, rest or travel, are not deemed resident even if they stay for more than six months.

Persons deemed resident in Türkiye are taxed as full taxpayers (tam mükellef) on all of their earnings derived inside and outside Türkiye (GVK m. 3). Article 20/D is a twenty-year exemption from this general rule for the foreign-source portion.

The Communiqué does not lay down a separate rule on which document establishes the settlement date or which day is taken as that date. The examples are based on a specific settlement date (for example 12 July 2026). The tax office checks the domicile and tax liability status in the three look-back years, whether the person is deemed resident in Türkiye and whether the application was made in time (333 Seri No.lu GVGT m. 3/4 and m. 4). It is therefore important to keep evidence in order from the outset, such as entry and exit records, the residence permit, documents showing that employment abroad has ended, and tax records in the previous country.

If the person later leaves Türkiye and ceases to be resident, the general rule applies again. As a limited taxpayer (dar mükellef), the person is taxed only on earnings derived in Türkiye (333 Seri No.lu GVGT m. 6).

Income Covered by the Exemption

The exemption covers only earnings and income derived outside Türkiye. Tax obligations continue for Turkish-source income (333 Seri No.lu GVGT m. 3/7).

Example 10 is important. In the Communiqué’s example, a person working as an engineer in Türkiye advises clients abroad on investments in Türkiye; the self-employment income from this service performed in Türkiye is not covered by the exemption. Receiving payment from a client abroad does not by itself determine the source of the income. For self-employment income, what matters is whether the activity is performed in Türkiye or evaluated (değerlendirme) in Türkiye (GVK m. 7/4). Conversely, transferring income earned abroad to a bank account in Türkiye does not make it Turkish-source either (333 Seri No.lu GVGT m. 6, Example 13). For the taxation of Turkish-source dividends, see our article on dividend withholding tax.

Consequences of the Exemption

• No annual tax return is filed for exempt foreign earnings. Even if a return is filed for other income, these earnings are not included in it (GVK mük. m. 20/D-3).
• Expenses and costs relating to these earnings cannot be deducted from income taxable in Türkiye (GVK mük. m. 20/D-4).
• Taxes paid abroad on these earnings cannot be credited against income tax calculated in Türkiye (GVK mük. m. 20/D-5).
• If it later emerges that the conditions were not met, taxes not assessed on time are deemed to have been lost (vergi ziyaı) (GVK mük. m. 20/D-6). According to the Communiqué, the tax is then claimed together with a tax loss penalty (vergi ziyaı cezası) and late payment interest (gecikme faizi) (333 Seri No.lu GVGT m. 5).

Application and Exemption Certificate

A person wishing to benefit from the exemption applies to the tax office authorised to assess tax (tarha yetkili vergi dairesi), i.e. the tax office to which they are attached for tax purposes. The person must be resident in Türkiye on the application date (333 Seri No.lu GVGT m. 3/2). If the conditions are met, the person is issued an “Exemption Certificate for Earnings and Income Derived from Abroad” (“Yurt Dışından Elde Edilen Kazanç ve İratlar İçin İstisna Belgesi”, Annex EK-1 to the Communiqué) (333 Seri No.lu GVGT m. 3/4 and m. 4).

A person who does not apply in time cannot benefit from the exemption. In one example in the Communiqué, no certificate is issued to a person who settled in 2028 and applied in 2030 (333 Seri No.lu GVGT m. 3, Example 2). The Communiqué does not list the documents required for the application one by one and does not prescribe a separate application form; the only form annexed to it is the exemption certificate issued by the tax office (EK-1). The tax office issues the certificate after establishing the domicile and tax liability status in the three look-back years, whether the person is resident in Türkiye on the application date and whether the application was made in time (333 Seri No.lu GVGT m. 4). In practical terms, it is useful to have documents ready with the application showing the settlement date and that the person lived abroad in the previous years.

Inheritance and Gift Tax Aspect

Article 2 of Law No. 7582 added a paragraph to Article 16 of the Inheritance and Gift Tax Law (Veraset ve İntikal Vergisi Kanunu, VİVK). Under it, for persons benefiting from the exemption under GVK Art. 20/D, a tax rate of 1% applies to transfers of property by inheritance (veraset yoluyla intikal) occurring within the exemption period (VİVK m. 16/3). This provision also took effect on the date of publication, i.e. 4 June 2026 (7582 s. Kanun m. 14/ç).

The reduced rate covers only transfers by inheritance, i.e. transfers on death. No separate reduction has been introduced for gratuitous transfers (ivazsız intikaller) taxable under the VİVK, i.e. gifts and similar acquisitions without consideration (VİVK m. 1). The general tariff applies to these transfers. Which assets fall within the scope of the VİVK is determined under the general rules. Assets located abroad should be assessed separately.

Relationship with Double Taxation Treaties

The exemption means that Türkiye does not exercise its own taxing right over foreign-source income. It does not remove the taxing right of the country where the income arises. The source country may continue to levy tax under its own legislation and, where applicable, the treaty (çifte vergilendirmeyi önleme anlaşması). This tax cannot be credited in Türkiye (GVK mük. m. 20/D-5).

If the person is treated as resident under domestic law both in Türkiye and in their previous country, the criteria in the residence article of the relevant treaty (such as permanent home and centre of vital interests) determine which country the person is a resident of. For treaty purposes, the position of a person treated as resident of the other country needs to be examined separately. Obtaining a certificate of residence (mukimlik belgesi) from Türkiye may also be necessary to claim reduced withholding tax in the other country. These matters vary by country and treaty. In each specific case, the text of the treaty in force and its protocol should be read.

Example: A Foreign National Moving to Türkiye in 2026

Assumptions (calendar year 2026):

• Mr A, a foreign national, lived and worked abroad in 2023–2025. In those years he had neither a domicile nor a tax liability in Türkiye.
• Since 2024 he has owned a flat in Istanbul, which he lets out. He has therefore been a taxpayer in Türkiye in respect of rental income (income from immovable property).
• On 15 March 2026 he moved to Türkiye, obtained a residence permit and spent the rest of the year in Türkiye. Because he stayed in Türkiye for more than six months in 2026 and came with the intention of settling, he is deemed resident in Türkiye (GVK m. 4).
• His income in 2026 (TL equivalents are hypothetical): dividends from a foreign company 2,000,000 TL; rent from his flat abroad 600,000 TL; rent from his flat in Istanbul 480,000 TL; a director’s fee from a Turkish company in which he is a shareholder 1,800,000 TL.

1. Settlement date: 15 March 2026, i.e. after 1 January 2026. The timing condition of the Law is met (7582 s. Kanun m. 14/a).
2. Three look-back years: 2023, 2024, 2025. There is no domicile in Türkiye. The only tax liability arose from rental income. This is not an obstacle (GVK mük. m. 20/D-2).
3. Application: Since he did not settle in the last two months of the year, the application deadline is 31 December 2026 (333 Seri No.lu GVGT m. 3/4).
4. Exempt income: 2,000,000 TL + 600,000 TL = 2,600,000 TL. This amount is not included in the tax return. Taxes paid abroad on this income are not credited in Türkiye.
5. Income taxed in Türkiye: rent from the Istanbul flat of 480,000 TL and the fee from the Turkish company of 1,800,000 TL, a total of 2,280,000 TL. The employer withholds tax on the fee through payroll according to the income tax tariff (GVK m. 103). The rental income is declared under the general provisions. Calculating the amounts under the 2026 tariff is outside the scope of this example.
6. Later years: As long as Mr A remains resident in Türkiye, his foreign-source earnings are exempt for twenty years. Even if he earns new employment or business income abroad in those years, that income is covered. An activity he starts in Türkiye, on the other hand, is taxed and does not breach the look-back condition (333 Seri No.lu GVGT m. 3, Example 3).

Had the same person been employed on the payroll of a company in Türkiye during 2023–2025, he would have had a tax liability on employment income and so could not obtain the certificate (333 Seri No.lu GVGT m. 3, Example 6).

Points to Note

• The text of the Law only says “for twenty years”. It does not separately specify in which calendar year the twenty years begin and in which year they end. The tax office’s view should be obtained on how the period is calculated.
• For a person who sets up a company in Türkiye and receives a salary or dividends from it, this income is Turkish-source and is not covered by the exemption. For company formation and shareholding structure, see our page on company formation with foreign shareholders.
• The same Law also contains a separate provision on the declaration of certain assets in Türkiye and abroad. This topic is covered in our article on the 2026 wealth amnesty.
• For personal tax returns and residence matters, see our pages on individual tax services and international tax advisory.

For your specific situation, you can write to us via our contact page.

Last legislation check: 9 November 2026 · Period covered: individuals deemed resident in Türkiye on or after 1 January 2026