Australians and Canadians Buying Property or Retiring in Turkey: The 2009 and 2010 Treaties, How Pensions and Superannuation Are Taxed, Property Income and Gains, and Where the Social Security Agreements Stop

Canada and Australia are Turkey's two newest Western treaty partners, and their treaties were written a generation after the American and British ones. That matters: the Canada treaty of 2009 lets Canada keep taxing a pension paid to a resident of Turkey, capped at fifteen per cent of the amount above twelve thousand Canadian dollars a year, while the Australia treaty of 2010 hands pensions and annuities to the state of residence outright and adds a special rule for superannuation lump sums taken before sixty. On the Turkish side both retirees meet the same law: a foreign social security pension is exempt from Turkish income tax by statute, a new resident's other foreign income is exempt for twenty years under the 2025 law, and property income, gains, inheritance and residence follow the rules on this site's Turkish pages. In my files the difference the two nationalities feel most is not in the tax treaties at all but in social security: Canada has had a social security agreement with Turkey since 2005 and Australia has none. This page sets out both treaties from their texts as in force in September 2026, the Turkish rules they interact with, and the points where the two nationalities part company.

Sources, checked 9 September 2026. Agreement between Canada and the Republic of Turkey for the avoidance of double taxation, signed at Ottawa on 14 July 2009, in force 4 May 2011 and applied from 1 January 2012, Articles 4, 6, 13, 18, 19, 21, 22 and 23; Convention between Australia and the Republic of Turkey, signed at Ankara on 28 April 2010, in force 5 June 2013 and applied in Turkey from 1 January 2014, Articles 4, 6, 13, 18, 19, 21 and 23; Turkish Revenue Administration list of treaties in force; Agreement on Social Security between Canada and Turkey, in force 1 January 2005; Income Tax Law No. 193, Article 23(13) and repeated Article 20/D; Land Registry Law No. 2644, Article 35; the Turkish property, inheritance and residence rules on the pages linked below.

Both may buy, and the same Turkish rules apply

Article 35 of the Land Registry Law admits foreign nationals of the countries the President designates, on the reciprocity and area limits explained on the buying guide, and Canadians and Australians have bought in Turkey under it for two decades. The Turkish side of the transaction is the same for both: the title deed types and the difference between a construction easement and full condominium ownership on the title deed page, the property tax and the valuable housing tax on the property tax page, the five-year rule on gains on the selling page, the reserved shares and the one per cent inheritance tax for new residents on the inheritance page, the bank and currency rules on the bank account page, and the residence and citizenship instruments on the golden visa page. What differs is what happens at home, and that is where the treaties come in.

Where the treaties agree

Both treaties use the same architecture for the questions a property owner asks first. Article 4 of each decides residence by the domestic law of each state and, where both claim the person, by the tie-breaker: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. Article 6 of each allows the state where real property is situated to tax income from it, which for a Turkish apartment means Turkey taxes the rent first and Canada or Australia gives credit. Article 13(1) of each allows the situs state to tax gains from the alienation of real property, so Turkey's five-year rule applies to the sale of the Turkish apartment and the home state credits Turkish tax paid; Article 13(4) of each extends that to shares deriving most of their value from Turkish real property, so holding the flat through a company changes nothing. Article 23 of each relieves double taxation by credit: Canada deducts Turkish tax on Turkish-source income from Canadian tax under Article 23(1), Australia credits Turkish tax under Article 23(1), and Turkey allows a deduction for Canadian or Australian tax under Article 23(2) of each treaty, within the limit of the Turkish tax attributable to that income. Article 21 of each sends other income to the residence state, the Canadian text allowing the source state to tax as well.

Where they part company: pensions

The Canada treaty. Article 18(1) allows the state of residence to tax pensions and annuities arising in the other state, and Article 18(2) then allows the source state to tax them too, capped for periodic pension payments at the lesser of fifteen per cent of the gross periodic payments in the calendar year that exceed twelve thousand Canadian dollars, or the rate the recipient would have paid as a resident of the paying state. Article 18(3) caps source-state tax on annuities at fifteen per cent of the taxable portion, with exceptions for surrendered annuities and deductible contracts; Article 18(4)(a) exempts war pensions in the residence state to the extent they would be exempt at home; and Article 19 keeps government salaries in the paying state while leaving government pensions to Article 18. For a Canadian retiree resident in Turkey, the Canada Pension Plan, Old Age Security and periodic registered retirement income fund payments remain taxable in Canada at up to fifteen per cent on the amount above twelve thousand dollars, in place of the higher non-resident rate Canadian law would otherwise apply, and Turkey then taxes or exempts them under its own law with credit for the Canadian tax. A lump-sum withdrawal from a registered plan is not a periodic pension payment and does not get the cap.

The Australia treaty. Article 18(1) provides that pensions, annuities and similar periodic remuneration paid to a resident of a contracting state are taxable only in that state, subject to Article 19(2) for government pensions, which are taxable only in the paying state unless the recipient is both a resident and a national of the other. Article 18(3) applies the same residence-only rule to lump sums paid in lieu of a pension, with one exception: a lump sum may also be taxed in the state in which it arises unless it is paid under a pension scheme to a member aged sixty or more. For an Australian retiree resident in Turkey, the Age Pension and a superannuation income stream are Turkey's to tax, and Australia's not; a superannuation lump sum taken after sixty is likewise Turkey's alone; a lump sum taken before sixty may be taxed by Australia as well as Turkey, with credit. The protocol adds that a departing Australia superannuation payment made to a former temporary resident is not a lump sum in lieu of a pension for this purpose.

What Turkey does with the pension it is allowed to tax

Turkey's domestic law then decides whether the pension the treaty allocates to it is taxed at all. Article 23(13) of the Income Tax Law exempts from income tax the retirement, disability, widows' and orphans' pensions paid by social security institutions located in foreign countries, which covers the Canada Pension Plan, Old Age Security and the Australian Age Pension. Repeated Article 20/D, in force since 2025 and explained on the Law 7582 page, exempts for twenty years the foreign-source income of a new resident who had not been Turkish resident in the preceding years and has no Turkish tax liability other than from Turkish rent, investment income or gains, which covers occupational pensions, registered retirement income fund payments and superannuation income streams for a retiree who qualifies and does not draw a Turkish salary. A Canadian or Australian who becomes Turkish resident in 2026 therefore pays, in the ordinary case, no Turkish tax on any of the pension income, and the only pension tax in the picture is the Canadian fifteen per cent on the amount above twelve thousand dollars, which nothing on the Turkish side relieves because there is no Turkish tax to credit it against. The Australian retiree, whose treaty gives Turkey the exclusive right and whose Turkish law does not exercise it, pays nothing in either country on the Age Pension and the superannuation stream, subject to the conditions of the exemption and to Australia's own residency rules for keeping the Age Pension abroad.

Social security: an agreement with Canada, none with Australia

The Agreement on Social Security between Canada and Turkey has been in force since 1 January 2005. It coordinates the Canada Pension Plan and Old Age Security with the Turkish system, lets periods in each country count toward eligibility in the other, and provides for the payment of benefits to residents of the other state; a Canadian who has not reached the residence periods Old Age Security requires for payment abroad may be helped by Turkish periods under it. Turkey's Social Security Institution lists Canada among its agreement partners and does not list Australia, and Australia's published list of agreement countries does not include Turkey. An Australian retiree in Turkey therefore takes the Age Pension abroad under Australia's own portability rules, which reduce the rate for those without a full Australian working life residence and which the retiree should have confirmed at home before leaving; Turkish periods do not help. Neither agreement changes the tax position above.

Property income and gains in practice

The Turkish apartment let to tenants produces rent that Turkey taxes under the rules on the landlord page, and that the home state taxes with credit under Article 6 and Article 23 of the treaty. The sale of the apartment produces a gain that Turkey taxes if the property is sold within five years of acquisition, and does not tax after, under the rules on the selling page; Canada and Australia tax the gain under their own rules with credit for whatever Turkey charged, and Australia's Article 13(5), which gives gains on other property to the residence state alone, does not reach real property. Article 22 of the Canada treaty allows the situs state to tax capital represented by immovable property, which is the treaty basis for Turkey's annual property tax and valuable housing tax on a Canadian owner. A Canadian or Australian who remains resident at home and merely owns in Turkey files in Turkey only for Turkish rent and gains, under the non-resident rules, and files at home on the world.

The two retirees compared

Whose side we are on, and how we are paid

The developer's agent in Toronto or Melbourne is paid on the sale and will tell a retiree that Turkey does not tax pensions, which is true, and will not mention that Canada keeps fifteen per cent of the pension above twelve thousand dollars whatever Turkey does. The financial adviser at home is paid on assets under management and may not know that Turkey exempts a new resident's foreign income for twenty years, which changes what should be drawn and when. Neither is paid to tell an Australian that Turkish years will not help the Age Pension, or a Canadian that a lump-sum withdrawal loses the treaty cap.

We take no commission or referral fee from developers, agents, banks or advisers, in any form, on any file. The fee you pay us is our only income from your matter, and it does not depend on your buying or moving. Because our position does not move with the sale, telling you to keep the pension in a form the treaty protects, or to wait a year before becoming resident, costs us nothing to say.

One boundary, stated plainly. We are lawyers, not licensed investment advisers and not Canadian or Australian tax agents. We do not compute your home-country return, advise on superannuation or registered plans as investments, or forecast currencies. What we protect is the Turkish legal position and the treaty position: which state may tax each income and at what cap, what Turkish law then exempts, and the property, inheritance, residence and banking rules that apply to you in Turkey.

Before you buy or move

Send us your nationality and current residence, the kinds of pension and other income you receive and who pays them, whether you intend to become Turkish resident and when, and any property you are considering. We will tell you which treaty articles apply to each income, what Turkey will and will not tax, whether the twenty-year exemption is available to you, and what the property, residence and inheritance rules require. Our residence and property work is described on the services page.

What this page does not settle

Canadian departure tax and the deemed disposition on ceasing residence, the Old Age Security residence requirements and clawback, Australian tax residency tests and superannuation preservation rules, the Age Pension portability schedule, the treatment of trusts and estates, and the position of dual nationals under Article 19 are separate subjects. Treaty texts are stable but domestic rules and the twenty-year exemption's conditions change; the positions above are those on the date checked.