Turkey's Double Tax Treaties in 2026: The Ninety-Three Partners on the Official List, Who Is Missing, What a Turkish Treaty Typically Caps, How Relief Is Claimed at Source and Refunded, and Why the Multilateral Instrument Does Not Yet Apply

Turkey has income tax treaties in force with ninety-three states and territories on the Revenue Administration's list, and the questions I am asked about them are rarely about the list. They are about whether a particular payment from Turkey can be reduced, what paper the Turkish payer needs before it applies the reduction, what happens when the paper arrives late, and whether the treaty an investor read ten years ago is still the one in force. In my files the treaty problems are procedural more often than substantive: a Dutch holding company taxed at fifteen per cent on a dividend because its residence certificate was for the wrong year, a Gulf investor who assumed a treaty existed with his country of residence when it did not, a British consultant refunded two years after the withholding because the request was filed after the payment rather than the form before it. This page gives the list as the Administration publishes it, the partners that are absent, the pattern most Turkish treaties follow with the three texts I use most, the mechanics of relief and refund, and the position of the OECD's multilateral instrument, which Turkey signed in 2017 and has not brought into force.

Sources, checked 9 September 2026. The Revenue Administration's list of double taxation agreements in force dated 23 April 2025; the Constitution, Article 90; Corporate Tax Law No. 5520, Article 35; Income Tax Law No. 193, Articles 3 and 4; Double Taxation Agreements General Communiqués Series No. 2 (Official Gazette 23286, 14 March 1998) and Series No. 4 (Official Gazette 30192, 26 September 2017); the Revenue Administration's explanatory page on taxation under the agreements; the Turkey-United States (1996), Turkey-United Kingdom (1986) and Turkey-Germany (2011) treaties; the OECD's table of signatories and parties to the Multilateral Convention, status as of 18 June 2026.

How a Turkish treaty comes into force, and why the dates matter

Communiqué Series No. 2 describes the sequence: the treaty is signed, submitted to the Grand National Assembly with its reasoning, approved by a law authorising ratification, ratified by decision, published in the Official Gazette, and enters into force on the exchange of instruments; its provisions then apply, in almost every case, to taxes for the years beginning on or after the following 1 January. The Administration's list therefore carries four dates for each partner, signature, Official Gazette, entry into force and first application, and the last is the one that matters for a return. Once in force the treaty prevails over domestic law: Article 90 of the Constitution gives duly ratified international agreements the force of law and excludes constitutional challenge to them, Article 35(3) of the Corporate Tax Law reserves the provisions of international agreements against the Law's own exemption rules, and the Administration's own guidance states that treaty rates are ceilings and that a lower domestic rate applies where Turkish law provides one. Several partners appear twice on the list because the original treaty was replaced: Austria's 1970 treaty by the 2008 one applied from 2010, Norway's 1971 treaty by the 2010 one applied from 2012, Finland's 1986 treaty by the 2009 one applied from 2013, Germany's terminated 1985 treaty by the 2011 one applied retroactively from 2011, Qatar's 2001 treaty by the 2016 revision applied from 2019, and South Korea's 1983 treaty by the 2021 revision applied from 2025. An investor working from an old copy applies the wrong text.

The list, by the partners who read this page

The remaining partners, several with treaties applied only recently, Sierra Leone and the revised South Korea treaty from 2025 among them, are Albania, Algeria, Azerbaijan, Bangladesh, Belarus, Bosnia and Herzegovina, Bulgaria, Cambodia, Chad, Croatia, the Czech Republic, Egypt, Ethiopia, Gambia, Georgia, Hungary, Indonesia, Iran, Jordan, Kazakhstan, Kosovo, Kyrgyzstan, Lebanon, Malaysia, Moldova, Mongolia, Morocco, North Macedonia, Northern Cyprus, Pakistan, the Philippines, Romania, Rwanda, Sierra Leone, Slovakia, Slovenia, South Korea, Sri Lanka, Sudan, Syria, Tajikistan, Thailand, Tunisia, Turkmenistan, Ukraine, Uzbekistan, Venezuela, Vietnam and Yemen. The list runs to ninety-three numbered entries because the Administration counts the State Union treaty twice.

Who is not on the list

Absence matters as much as presence, and a reader from one of these places should plan on domestic law alone. There is no treaty in force with the Republic of Cyprus, Iraq, Libya, Nigeria, Colombia, Chile, Peru or Hong Kong, and none with any Caribbean or Channel Islands jurisdiction. For a company in such a place that receives a payment from Turkey, the rates on the withholding tax page apply without reduction, and a Turkish resident with income from there relies on the unilateral foreign tax credit of the domestic law rather than on a treaty. A treaty with a holding jurisdiction does not help a beneficial owner elsewhere: every Turkish treaty limits its dividend, interest and royalty articles to the beneficial owner, and the Administration examines the residence certificate of the recipient, not of the group.

What a Turkish treaty typically does

Turkey negotiates on a model that mixes the OECD and United Nations texts, and the pattern in the three treaties I read most often holds across most of the list. Dividends are taxed in the source state at a cap that distinguishes a corporate shareholder with a substantial holding from everyone else: fifteen and twenty per cent in the American and British treaties, five and fifteen in the German. Interest is capped at fifteen per cent in the American and British treaties, ten in the German, with lower rates for financial institutions in the American text. Royalties are capped at ten per cent in all three, with five per cent for equipment rentals in the American. A building site becomes a permanent establishment after six months in all three, and the German treaty adds a service permanent establishment after six months of personnel presence in twelve; the American and British treaties reach services through a 183-day rule for enterprises. Capital gains on property and permanent establishment assets are taxed at source, and all three keep a Turkish right to tax gains on other property held one year or less, the American one limited to unlisted Turkish shares and bonds sold to a Turkish resident. Private pensions are generally taxable only in the state of residence, with the exceptions and the social security clauses set out on the US treaty page, the UK treaty page and the Australians and Canadians page. What these caps do against the domestic rates, dividend by dividend and royalty by royalty, is worked through on the dividend withholding page and the capital gains page. Two cautions apply to every other partner on the list: the rates and holding thresholds differ treaty by treaty and must be read in the text, and the older treaties, several of them signed in the 1980s, carry definitions and article numbering of their own.

Claiming relief at source: the certificate and the forms

Turkish relief is applied by the payer, not by the tax office, and the payer applies it only on paper it can defend at an audit. Communiqué Series No. 4 sets the standard. The foreign recipient obtains a certificate of residence from the competent authority of its own state, and delivers the original with a Turkish translation certified by a notary or a Turkish consulate to the Turkish payer, who keeps it for the Administration; without it the payer must apply domestic law whatever the treaty says. A certificate for a calendar year is valid until the fourth month of the following year, so a standing relationship needs a new certificate each spring. Where the treaty leaves Turkey no tax at all, as it does for most service fees, the recipient completes the communiqué's form no. 1 within thirty days of the start of the service and the payer files form no. 2 with its tax office before the first payment; where the payer cannot clearly establish at the time of payment that the treaty removes the Turkish right, for instance because the length of a stay is not yet known, it must withhold and leave the recipient to the refund. The Administration applies the same certificate discipline to dividends, interest and royalties, and a Turkish bank paying interest or a Turkish company paying a dividend abroad will ask for the certificate before it applies a cap. A Turkish resident who needs to prove residence abroad obtains the Administration's own certificate of residence, which the communiqué contemplates in the other direction and which is issued on application.

Refunds, and why they are the second-best route

Where tax was withheld at the domestic rate and the treaty allowed less, section 5 of Communiqué No. 4 lets the recipient, personally or through a representative, apply to the tax office for a refund with the residence certificate and form no. 3, within the correction limitation period of the Tax Procedure Law unless the treaty sets its own, and the request is processed under domestic refund rules. The route works and I have used it, but a refund of Turkish tax to a foreign claimant is a documented, slow procedure, and the sum sits in Ankara while it runs. The paper before the payment is worth more than the claim after it. For a Turkish resident taxed abroad the mirror image applies: the foreign tax is credited in Turkey under the treaty's relief article and the domestic credit rules, on proof of payment, and the excess is not refunded by Turkey.

The multilateral instrument, signed and not in force

Turkey signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures on 7 June 2017, and the OECD's table of signatories and parties, in its version of 18 June 2026, still shows no deposit of ratification and no entry into force for Turkey. The practical consequence is that Turkey's treaties apply as bilaterally negotiated: the principal purpose test, the changes to the permanent establishment definition and the dual-residence tie-breaker that the instrument would import have not entered Turkey's treaties through that route, and an investor should not read the OECD's synthesised texts as Turkish law. Anti-abuse language exists only where a particular treaty contains it, and the beneficial ownership condition and the domestic anti-avoidance rules do the work that the instrument does elsewhere. If Turkey deposits its instrument the position changes for the treaties both parties have listed, and the date of effect will follow the instrument's own timing rules; until then, the bilateral text governs.

Residence, the other half of every treaty question

A treaty allocates taxing rights between states of residence, and the first question is always where the person is resident under each state's law. Article 3 of the Income Tax Law taxes residents on worldwide income and Article 4 treats as resident anyone whose domicile is in Turkey or who stays in Turkey continuously for more than six months in a calendar year, temporary absences not interrupting the count; a company is resident where its legal seat or place of management is. A person resident under both states' laws is assigned by the treaty's tie-breaker, permanent home, centre of vital interests, habitual abode and nationality, and that assignment governs the whole treaty. Foreign nationals who become Turkish residents should read the twenty-year exemption on the Law 7582 page before they rely on a treaty at all, and companies on the corporate tax page. The parallel network on the other side of the Adriatic is on the Montenegro treaty page.

Whose side we are on, and how we are paid

The Turkish payer's accountant applies whatever rate is in the system. The foreign recipient's adviser reads the treaty and not the communiqué. The bank asks for the certificate on the day of the transfer. None of them is paid to tell you that the certificate covers the wrong year, that the form was due before the payment, or that the country you moved to has no treaty with Turkey at all.

We take no commission or referral fee from accountants, banks or corporate service providers, in any form, on any file. The fee you pay us is our only income from your matter, and it does not depend on whether a treaty applies or how much it saves. Because our position does not move with the outcome, telling you that the domestic rate is already below the treaty cap, or that there is no treaty to rely on, costs us nothing to say.

One boundary, stated plainly. We are lawyers, not licensed investment advisers and not your home-country tax preparers. We do not tell you what your own state will credit or whether to invest in Turkey at all. What we protect is the Turkish legal position: which treaty is in force and which text, the article and the cap that fit the payment, the certificate and forms that make the relief hold on inspection, the refund when the paper was late, and the residence position on which everything else depends.

Before the first cross-border payment

Send us the payer, the recipient, the recipient's country of residence and legal form, the type and timing of the payment, and any residence certificate already in hand. We will tell you whether a treaty is in force and which text, what it caps or removes, what the payer must hold before paying and what to file if it does not, and how to recover any excess already withheld. Our cross-border tax work is described on the international tax page.

What this page does not settle

The article-by-article terms of the ninety-odd treaties not quoted here, the tax information exchange agreements that sit beside them, the social security agreements, which are a separate network, the treaty positions of trusts and partnerships, and the home-country side of every relief are separate subjects. The list changes as new treaties enter into force and old ones are revised; the entries above are those on the Administration's list on the date checked.