Two groups of people write to me about Turkey's new twenty-year exemption more than any other. The first are Turkish citizens who have lived for years in Germany, the Netherlands, France, the United Kingdom or the United States and are thinking about a permanent return. The second are foreigners who already lived in Turkey once, many of them between 2022 and 2024, left, and now want to come back. Both assume the exemption is written for someone else, and I understand why. For many of them it is not, but the law draws a line through both groups, and the line runs through calendar years they have already lived.
This page applies repeated Article 20/D of the Income Tax Law and Communiqué No. 333 to people with a Turkish past. The rule itself, and what it exempts, is on Turkey's 20-year exemption on foreign income. The application procedure and its deadline are on the exemption certificate page. What follows is narrower: whether your own history keeps the door open, and what to do about the parts of that history you can still influence.
Sources, checked 16 September 2026. Income Tax Law No. 193, repeated Article 20/D and Articles 3, 4, 5, 7 and 23, consolidated text on mevzuat.gov.tr; Income Tax General Communiqué Series No. 333, Official Gazette No. 33300 of 4 July 2026, Articles 3 to 6 and Examples 1 to 13; Law No. 7582, Article 14, Official Gazette No. 33270 of 4 June 2026; Civil Code No. 4721, Articles 19 to 21; Population Services Law No. 5490, Articles 50 to 52.
Nationality is not a condition
Article 20/D speaks of natural persons settled in Turkey. It does not mention nationality, and Communiqué No. 333 adds none. A Turkish citizen who returns after thirty years abroad is in exactly the same position as a Dutch or Canadian national who has never set foot in Turkey, provided the three-year record is clean.
There is one place where nationality does matter, and it works against citizens. Article 5 of the Income Tax Law says that certain foreigners are not treated as settled even if they stay more than six months: people who come for a defined temporary job, and people who come for study, medical treatment, rest or travel. The article is written for foreigners only. A Turkish citizen who spends more than six months in Turkey in a calendar year cannot argue that the stay was a long holiday. For the returning citizen that is usually helpful, because it makes settlement easy to prove; for the citizen who wanted to test the water before committing, it means the test itself can trigger settlement.
The three-year look-back applied to a Turkish past
The condition is the same for everyone. In the three calendar years before the year you become settled, you must have had neither a domicile nor a tax liability in Turkey. Example 4 of the communiqué is the one written for returners: a person domiciled in Turkey in 2022 left on 10 November 2024 and moved their domicile back in 2027. The certificate was refused, because the person was settled in Turkey in 2024 and 2024 lies inside the window.
Two things follow. First, the year you left counts as a year in Turkey, even if you left in November. Second, the counting is by calendar year, so the earliest year you can come back and qualify is four calendar years after the last year you were settled here.
| Last calendar year you were settled in Turkey | Clean years needed | Earliest year of settlement that can qualify | Certificate deadline |
|---|---|---|---|
| 2022 or earlier | 2023, 2024, 2025 | 2026 | 31 December 2026 (end of February 2027 if settled in November or December) |
| 2023 | 2024, 2025, 2026 | 2027 | 31 December 2027 |
| 2024 | 2025, 2026, 2027 | 2028 | 31 December 2028 |
| 2025 | 2026, 2027, 2028 | 2029 | 31 December 2029 |
The table assumes nothing else happened in the clean years. The next sections are about the things that do happen.
A limit of the text should be stated here. Example 4 concerns someone who left in November. The communiqué does not say how a year is treated if you gave up a Turkish domicile in January or February and spent the rest of the year abroad. On the wording of Article 4 you were domiciled in Turkey for part of that year, and I would plan on that year counting.
Domicile: the address you left behind
For a returning citizen the most common problem is not a job or a company but an address. Many people who moved abroad decades ago never updated the population register, and their record still shows a parent's flat in Konya or Trabzon.
The legal test of domicile is in the Civil Code, not in the register. Article 19 defines domicile as the place where a person lives with the intention of staying permanently, and no one has more than one at a time. Article 20 adds that a domicile is changed only by acquiring a new one. A citizen who has lived and worked in Stuttgart for twenty years has a domicile in Stuttgart, whatever the register says.
The register still matters, because it is what the tax office sees first. Article 50 of the Population Services Law makes a person's written declaration the basis of the address record and allows the declaration to be made at Turkish consulates abroad, Article 51 requires changes to be reported within twenty working days, and Article 52 tells public bodies to rely on the address data held centrally. A Turkish address that stayed in the register for the look-back years does not make you domiciled in Turkey, but it gives the tax office a reason to ask, and the answer will have to come from documents: foreign registration certificates, foreign tax returns, employment records, school records of children.
What you can influence is the future, not the past. If you are still abroad, updating the register to your foreign address through the consulate is a step I would take before planning a return, because it removes a contradiction from the years that will be examined later.
Tax liability: which Turkish income blocks you and which does not
The second half of the condition is the absence of a Turkish tax liability. The law carves out three kinds of income: a liability that arose only from Turkish rental income, investment income or capital gains does not block the certificate. The carve-out fits returning citizens well, because many of them own a flat in Turkey and let it.
| Turkish income in the look-back years | Effect on the certificate |
|---|---|
| Rent from a flat in Turkey, declared (Example 5) | Does not block |
| Interest on Turkish bank deposits, taxed by withholding | Investment income; does not block |
| Dividends from Turkish shares, gains on selling Turkish property | Investment income and capital gains; do not block |
| Salary from a Turkish employer, even one job with withholding (Example 6) | Blocks |
| Trading or business income registered in Turkey (Example 7) | Blocks |
| Fees for professional work invoiced in Turkey | A liability outside the carve-out; I would treat it as blocking |
Example 6 is the one that surprises returners. The person in it had earned a salary from a single Turkish employer, taxed at source, in one of the look-back years. The communiqué still treated that as a tax liability and refused the certificate. A summer contract, a semester of teaching, a few months on a Turkish payroll while visiting family: each of these can close the door for three years.
Turkish citizens posted abroad by Turkish employers
Article 3(2) of the Income Tax Law contains a rule that most returners have never heard of. Turkish citizens who live abroad because they work for Turkish public bodies or for organisations whose head office is in Turkey are taxed in Turkey on their worldwide income, as if they were resident, unless they were taxed on that income where they lived.
A diplomat, a Turkish bank's branch employee in London or a Turkish contractor's site manager in the Gulf may therefore have been fully liable to Turkish income tax during the very years they think of as years abroad. Communiqué No. 333 does not address this group. On the wording of Article 20/D, a Turkish tax liability in the look-back years is a Turkish tax liability, whatever its basis, and I would not advise anyone in this position to assume the certificate will be granted without a written analysis of their own years.
Foreigners who lived in Turkey before
The same arithmetic applies to foreign nationals who held Turkish residence permits and left. A great many people moved to Turkey from Russia, Ukraine, Iran and elsewhere in 2022 and 2023, stayed for a year or two, and moved on. For them the key question is the last calendar year in which they were settled in Turkey under Article 4, and the table above gives the earliest possible return year.
Three points are specific to foreigners. First, a residence permit does not by itself prove or disprove settlement; the tax test is domicile or more than six months in a calendar year. Second, on its wording Article 5 can help a foreigner who stayed in Turkey only for study or treatment: such a stay is not settlement, so it should not use up a look-back year, although I would expect the tax office to look closely at any Turkish address registered during that time. Third, a foreigner who worked remotely from Turkey for a foreign employer during those years may have had a Turkish tax liability they never registered; the source rule in Article 7(3) of the Income Tax Law treats wages as Turkish when the work is performed in Turkey. An unregistered liability discovered later is exactly the situation in Example 12, where a certificate is cancelled back to the date of settlement.
What the exemption gives a returner, and what it does not
For a returner who qualifies, the exemption works as for anyone else. Rent from the flat in Rotterdam, dividends from a German share portfolio, interest on a French savings account and gains on selling foreign property during the twenty years are exempt from Turkish income tax and are not declared in Turkey.
Two points are specific to returners. Pensions paid by foreign social security institutions, such as the German statutory pension, were already exempt in Turkey under Article 23(1)(13) of the Income Tax Law before 2026; for many returning pensioners the exemption adds less than they expect on that item and more on everything else. And income from Turkey stays taxable: rent from the flat in Turkey, Turkish dividends at 15% withholding, and wages or fees for work performed in Turkey, as Examples 9 to 11 show.
The exemption also says nothing about the country you are leaving. Whether Germany, the Netherlands or the United Kingdom continues to tax your pension, your rent or your gains after you move is decided by its law and its treaty with Turkey. The same person can be settled in Turkey under Article 4 and still resident under the domestic law of the other country; treaties resolve that conflict with their own tie-breaker rules.
A sequence for a planned return
- Reconstruct your last three calendar years before the intended year of return: Turkish addresses in the register, any Turkish tax number, any Turkish salary, fees or business, any posting by a Turkish employer.
- If a year in that window is problematic, move the return year, not the facts. The calendar table above shows the earliest year that works.
- While still abroad, update the population register to your foreign address through the consulate, so that the record matches the years that will be examined.
- In the year of return, establish a documented domicile and register the address, then file the petition for the certificate with the tax office of your domicile before 31 December, or before the end of February if you returned in November or December.
- Keep Turkish income separate from foreign income from the first day, because only the foreign part leaves your return.
Whose side we are on, and how we are paid
Returning home is often handled by people who earn from the return: the developer selling the new flat, the relocation service, the bank that will hold the transferred savings. We take no commission from any of them, in any form, on any file. Our only income from your matter is the fee you pay, and it does not rise if you return this year rather than in three years. So we can tell you that your return year should move, without any reason to say otherwise.
We are lawyers, not licensed investment advisers and not tax advisers in the country you are leaving. We do not give personal investment advice on financial instruments, and we do not advise on the tax law of Germany, the Netherlands or any other country of departure. We examine your Turkish record, fix the Turkish facts that can still be fixed and prepare the certificate file.
Before you book the move
Send us the list of your Turkish addresses, tax numbers, Turkish income and Turkish employers for the last five calendar years. We will tell you in writing which year of return keeps the twenty-year exemption open and what has to happen before then. Our Turkish tax work is on the international tax page, and our work on succession and family assets for returning families is on the wealth management page. Pension-specific questions are also covered in retiring to Turkey, and the position of people who keep working remotely in the remote salary page.
What this page does not settle
It does not settle how a year is treated when a Turkish domicile was given up early in that year; Example 4 covers only a November departure. It does not settle whether worldwide liability under Article 3(2) for citizens posted abroad counts as a Turkish tax liability for Article 20/D, because the communiqué does not address it. It does not settle how any other country taxes you after you leave it.
