When a business owner moves to Türkiye, tax planning often starts with foreign dividends or rent. Eligibility for the 20-year exemption first depends on the individual’s history: where they lived, what Turkish tax obligations they had and when they became settled in Türkiye for tax purposes.
An old Turkish address registration needs examination. It is insufficient on its own either to reject relief or to conclude that relief has been secured. The Istanbul tax administration’s ruling of 13 October 2026, No. E-62030549-120-1372289, addresses this distinction.
What the exemption covers
Repeated Article 20/D of Income Tax Law No. 193 provides a 20-year exemption for individuals’ foreign income, subject to conditions. It applies to individuals becoming settled in Türkiye from 1 January 2026 onward. In the preceding three calendar years, they must not have had a Turkish domicile or a Turkish tax status that prevents eligibility.
This is personal relief. It does not exempt a Turkish company’s profits from corporate tax. The individual’s Turkish income remains subject to the ordinary rules. Turkish relief also does not remove tax obligations in the source country.
Address registration and actual residence
Article 4 links settlement in Türkiye to domicile or continuous presence exceeding six months in a calendar year; temporary departures do not interrupt that period. Domicile refers to Article 19 of the Civil Code: the place where someone lives with an intention to remain permanently.
The October ruling considers Turkish citizens who lived abroad under a work or residence permit. Where they substantiate that permit and presence abroad for more than six months in the relevant calendar years, a retained Turkish address does not by itself breach the preceding-three-years domicile condition. They must also substantiate their definitive return and settlement in Türkiye from 1 January 2026 onward. The remaining conditions require separate examination.
This conclusion should not be extended automatically to every foreign national or dual citizen. The ruling does not separately explain which evidence replaces a permit for someone living in a country of which they are also a citizen. Nor does it establish a universal settlement date for everyone moving to Türkiye.
Case: an address remains and an apartment is rented out
Consider a Turkish-citizen owner who has lived abroad with their family for several years, retains a Turkish address and declares rent from a Turkish apartment. If they return in 2026, the relevant preceding calendar years are 2023, 2024 and 2025. The test is not simply a rolling 36 months from arrival.
The law expressly distinguishes prior Turkish tax registration arising from property income, investment income or capital gains: it does not itself prevent relief if the other conditions are met. Rental income therefore cannot be treated as equivalent to every other form of tax history.
Salary and business activity require a different assessment. GİB’s guide gives refusal cases involving Turkish salary, including income subject to withholding by a single employer, or business-income tax obligations within the preceding three-year period. Not filing a personal return does not establish the absence of a disqualifying tax status.
When to apply
Applicants must approach the competent tax office for an exemption certificate, İstisna Belgesi. They must already be settled in Türkiye when applying. The application is due by the end of the relevant calendar year. Individuals becoming settled in November or December have until the end of February of the following year.
| Settlement under the tax rules | Application deadline |
|---|---|
| January–October 2026 | 31 December 2026 |
| November–December 2026 | End of February 2027 |
GİB expressly describes refusal where the application is late. Establish the settlement date before the deadline passes. A change in the settlement year also changes the three preceding calendar years under examination.
What to prepare before filing
Build a residence and travel timeline for each relevant year. Reconcile it with work or residence permits and the person’s Turkish tax history. Border records, foreign tax-residence documents, employment and housing records, and evidence of the actual move may help the discussion with an adviser. This is a working evidence list, not an exhaustive list guaranteed to satisfy the tax office.
Classify future income separately. A foreign payer or a foreign-currency account does not replace an examination of the income’s source. Retain evidence after the certificate is issued: if eligibility is subsequently found to have been absent, additional tax, penalties and interest may follow.
Start by checking the preceding three calendar years, supporting the settlement date and recording the filing deadline. Then calculate the personal tax effect of the move.
Official sources
- Istanbul tax administration ruling of 13 October 2026, No. E-62030549-120-1372289: Article 20/D, quoted statutory and Communiqué No. 333 provisions, address records and residence abroad.
- GİB guide to the foreign income exemption, September 2026: eligibility, filing, cases and consequences of non-compliance.
Checked on 21 October 2026. An özelge states the administration’s position on a particular request; it does not replace an assessment of another applicant’s circumstances.