The twenty-year exemption on foreign income does not apply to anyone automatically. It applies to people who hold a certificate, and the certificate has to be requested inside a window that closes at the end of the year you move. The rules for that request are not in the law but in Income Tax General Communiqué Series No. 333, published in the Official Gazette on 4 July 2026. It is eight articles long, it has one annex and thirteen worked examples, and it is the document the tax office will read when your petition arrives.
This page is about that communiqué and nothing else. What the exemption covers, and what stays taxable, is on Turkey's 20-year exemption on foreign income; where the exemption sits in its law is on Law 7582, article by article. Here I go through the procedure in the order you will live it, and I say plainly where the communiqué is silent.
Sources, checked 16 September 2026. Income Tax General Communiqué Series No. 333, Official Gazette No. 33300 of 4 July 2026, Articles 1 to 8 and Annex 1; Income Tax Law No. 193, repeated Article 20/D and Articles 3, 4, 5 and 106, consolidated text on mevzuat.gov.tr; Law No. 7582, Article 14, Official Gazette No. 33270 of 4 June 2026.
What the communiqué contains
| Article | Subject | What it does |
|---|---|---|
| 1 | Purpose and scope | Procedures for repeated Article 20/D of the Income Tax Law |
| 2 | Legal basis | Reproduces Article 20/D in full |
| 3 | Who benefits, conditions, special cases | Ten paragraphs: look-back, settled at application, from 1 January 2026, certificate and deadline, prior rent and investment income, no declaration, Turkish income stays taxable, costs, foreign tax credit, natural persons only; Examples 1 to 11 |
| 4 | What tax offices do | Four checks before issuing the certificate |
| 5 | Persons found not to qualify | Assessment with loss-of-tax penalty and late-payment interest; Example 12 |
| 6 | Other matters | Persons who are not, or stop being, resident; Example 13 |
| 7 and 8 | Entry into force and execution | In force on publication, 4 July 2026 |
| Annex 1 | Exemption certificate | Model of the letter the tax office issues |
Step 1: become settled before you apply
Article 3(2) makes the order of events a condition: you must be treated as settled in Turkey on the date you apply. A petition sent from abroad before you have moved is premature, whatever your plans.
Settled means the test in Article 4 of the Income Tax Law: a domicile in Turkey, or a continuous stay of more than six months within one calendar year, with temporary absences not breaking the count. Article 5 excludes foreigners who come for a defined temporary job or for study, treatment, rest or travel. The communiqué's examples speak of a person "settled on" a given date, but neither the communiqué nor the law says how that date is fixed when settlement comes from the six-month rule rather than from a registered domicile. That is one reason I prefer to anchor a client's settlement to a documented domicile.
Article 3(3) adds the date filter from Law 7582, Article 14(a): only persons settled in Turkey from 1 January 2026 can benefit.
Step 2: check the three calendar years before the year of settlement
Article 3(1) repeats the condition of the law: no domicile and no tax liability in Turkey in the last three calendar years before the year you are settled. Article 3(5) repeats the carve-out: a prior liability that arose only from Turkish rental income, investment income or capital gains does not block the certificate.
Before you file, build the three-year record from documents: registered addresses, any Turkish tax number and what it was opened for, any payroll record, any company office held. The examples below show that the tax office will treat one withheld salary as a disqualifying liability.
Step 3: apply to the right tax office before the deadline
Article 3(4) sets both where and when. You apply to the tax office competent to assess your income tax. For a person fully liable to income tax, Article 106 of the Income Tax Law gives that competence to the tax office of the place of domicile. The application is a written petition; the communiqué does not prescribe a form for it and does not mention an online channel.
The deadline is the end of the calendar year in which you became settled. If you became settled in November or December, it is the end of February of the following year.
| You became settled in | Last day to apply |
|---|---|
| January to October 2026 | 31 December 2026 |
| November or December 2026 | 28 February 2027 |
| January to October 2027 | 31 December 2027 |
| November or December 2027 | 29 February 2028 |
| January to October 2028 | 31 December 2028 |
Example 2 shows what happens after that: a person settled on 2 March 2028 who applied on 1 May 2030 received no certificate. The communiqué contains no late-filing route. For people who settled in the first months of 2026, before the law was published, the first row is the one that matters, and it is already running.
Step 4: what the tax office checks
Article 4 lists the checks. The office verifies whether you had a domicile or a tax liability in Turkey in the three calendar years before settlement, whether you are settled in Turkey, and whether you applied in time. If all hold, it issues the certificate.
In practice I send the petition with the evidence those checks will need, rather than waiting for the office to ask: the address registration record, entry and exit records if the six-month rule is in play, foreign tax residence certificates or returns for the three look-back years, and a short statement of any Turkish income in those years with its type, so that the rental-income carve-out is visible on the face of the file. None of this list is written in the communiqué; it is the file I would want to defend later.
Annex 1: what the certificate actually says
Several guides describe Annex 1 as an application form. It is not. Annex 1 is the model of the letter the tax office sends back: it is addressed from the tax office directorate, refers to "your petition dated …", restates Article 20/D, and states that the certificate is issued under Communiqué No. 333.
Two sentences in it deserve attention. The certificate says that if a situation contrary to the matters stated in your petition is found, or emerges later, you will be personally liable for the lost tax and the related penalty, interest and surcharges. And it says that sanctions apply if the procedures in the communiqué are not followed. In other words, the certificate is issued on the strength of what you declared, and the risk of an inaccurate petition stays with you.
The thirteen examples in one table
| Ex. | Facts | Outcome |
|---|---|---|
| 1 | Settled 12 July 2026; no Turkish liability or domicile in 2023 to 2025; applied 1 December 2026 | Certificate issued |
| 2 | Settled 2 March 2028; clean 2025 to 2027; applied 1 May 2030 | Refused: late |
| 3 | Settled 12 May 2028; starts a retail clothing business in Turkey on 30 October 2028; applied 15 November 2028 | Issued if 2025 to 2027 are clean |
| 4 | Domicile in Turkey in 2022; left 10 November 2024; domicile back in Turkey in 2027 | Refused: resident in 2024 |
| 5 | Settled 12 May 2028; declaring Turkish rent since 7 May 2026 | Issued: rental liability does not block |
| 6 | Settled 23 July 2028; salary from one Turkish employer with withholding in 2026 | Refused |
| 7 | Settled 15 September 2028; Turkish trading income liability since 1 January 2026 | Refused |
| 8 | Certificate holder with Turkish rent, Turkish investment income and rent from property abroad | Foreign rent left out of the Turkish return |
| 9 | Certificate holder letting property in Turkey | Turkish rent taxable |
| 10 | Certificate holder, engineer in Turkey, consulting clients resident abroad on their Turkish investments | Fees taxable |
| 11 | Certificate holder: 600,000 TL Istanbul rent and 500,000 TL dividend from a Turkish company; dividend from a Spanish company and rent in Monaco | Turkish items declared; foreign items exempt and not declared |
| 12 | Certificate issued 1 December 2026; audit in 2027 finds unregistered trading in 2025 and 2026 | Certificate cancelled from settlement date 12 May 2026; tax, loss-of-tax penalty and interest |
| 13 | Resident of the United Arab Emirates, not settled in Turkey, transfers 100,000 US dollars and 50,000 euros of French rent into a Turkish account | Not taxable in Turkey |
Example 3 is worth a second look because it answers a question clients ask: can I start a business in Turkey after I move? Yes. Starting Turkish trading activity after settlement does not affect the certificate; the look-back is about the three years before. The trading income itself is Turkish-source and taxable like anyone else's.
After the certificate
Article 3(6) and (8) to (9) set the running rules. Exempt foreign income is not declared, and it is left out of any return you file for Turkish income. Costs relating to it are not deductible. Foreign tax on it is not credited. Article 3(7) keeps Turkish income fully taxable, and Article 3(10) keeps companies out.
Article 5 is the long tail. If the tax office later establishes that the conditions were not met, it assesses the tax that was not accrued, with a loss-of-tax penalty and late-payment interest. Example 12 shows the certificate cancelled back to the settlement date, not to the date of discovery.
Article 6 covers leaving. A person who stops being resident is taxed in Turkey only on Turkish income under the general rule of Article 3 of the Income Tax Law, certificate or not.
If the application is refused
The communiqué says nothing about refusals. A refusal is a written administrative act of the tax office, and it can be challenged; the time limit for challenging it runs from notification and is short, so the refusal letter should go to a lawyer on the day it arrives. Before that stage, the more useful step is the one above: a petition that already answers the four checks leaves less room for a refusal based on missing information.
Whose side we are on, and how we are paid
The people most eager to file this petition for you are usually paid by the move itself: relocation firms, developers selling the flat that becomes your domicile, banks opening the accounts. 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 move. That is why we can tell you, before you register an address, that the look-back or the deadline has already closed the door, without anything to lose by saying it.
We are lawyers, not licensed investment advisers and not tax agents in the country you are leaving. We do not give personal investment advice on financial instruments. We prepare and defend the Turkish file: the settlement facts, the petition, the certificate and the dates.
Before you file
Send us your intended settlement date, your registered or planned Turkish address, and the documents for the three look-back years. We will tell you in writing which deadline applies to you, whether anything in the record will block the certificate, and what the petition should attach. Our Turkish tax work is on the international tax page. If you will keep running a company after the move, read moving to Turkey with a foreign company before you file; if you will keep working for a foreign employer, read the remote salary page.
What this page does not settle
It does not settle how the date of settlement is fixed when it follows from the six-month rule rather than a registered domicile; the communiqué uses dates without saying how they are found. It does not settle whether an online filing channel exists for this petition, because the communiqué names none. It does not settle the time limit and court for challenging a refusal in a particular case.
