Implementation Principles of the 20-Year Income Tax Exemption for Income and Gains Derived Abroad
13 August 2026
The General Communiqué No. 333 on Income Tax (“Communiqué”), published in the Official Gazette dated 4 July 2026 and numbered 33300, sets out the procedures and principles regarding the income tax exemption applicable to income and gains derived abroad under Repetitive Article 20/D of the Income Tax Code introduced by Law No. 7582.
As previously announced, pursuant to Repetitive Article 20/D of the Income Tax Code, income and gains derived outside Türkiye by certain individuals who satisfy the prescribed conditions and become resident in Türkiye are exempt from income tax for a period of 20 years.
The Communiqué provides detailed explanations regarding the persons eligible for the exemption, the application process, the procedures for obtaining the exemption certificate, the types of income falling within the scope of the exemption and other matters of practical importance.
This Tax Alert summarises the regulations introduced by the Communiqué together with their practical implications.
As previously announced, pursuant to Repetitive Article 20/D of the Income Tax Code, income and gains derived outside Türkiye by certain individuals who satisfy the prescribed conditions and become resident in Türkiye are exempt from income tax for a period of 20 years.
The Communiqué provides detailed explanations regarding the persons eligible for the exemption, the application process, the procedures for obtaining the exemption certificate, the types of income falling within the scope of the exemption and other matters of practical importance.
This Tax Alert summarises the regulations introduced by the Communiqué together with their practical implications.
What Does the Regulation Cover?
General Communiqué No. 333 on Income Tax sets out the procedures and principles for the implementation of Repetitive Article 20/D of the Income Tax Code, introduced by Article 4 of Law No. 7582.
Under the relevant provision:
What Is the Purpose of the Regulation?
The main purpose of the regulation is to encourage individuals residing abroad who plan to relocate to Türkiye to return to Türkiye and to increase Türkiye's attractiveness for qualified human resources and capital by reducing the tax burden on their foreign-source income.
Within this framework, income and gains derived abroad by individuals satisfying the relevant conditions are exempt from income tax for 20 years, notwithstanding that such individuals are considered fully liable taxpayers in Türkiye.
However, the Communiqué makes it clear that the exemption does not apply automatically. In order to benefit from the exemption, all conditions prescribed under the Communiqué must be satisfied and an Exemption Certificate must be obtained.
Who May Benefit from the Exemption?
Pursuant to General Communiqué No. 333 on Income Tax, the income tax exemption is available only to individuals. Corporate income taxpayers cannot benefit from this exemption.
The following conditions must be satisfied simultaneously in order to benefit from the exemption:
Examples Provided in the Communiqué
Example 1 – Issuance of an Exemption Certificate Where the Conditions Are Satisfied
In the first example provided in the Communiqué, (A), who became resident in Türkiye on 12 July 2026, applied to the tax office on 1 December 2026 to obtain an exemption certificate.
As a result of the examination conducted by the tax office, it was determined that the taxpayer had neither a residence nor an income tax liability in Türkiye during the 2023, 2024 and 2025 calendar years. Accordingly, the taxpayer would be issued an Exemption Certificate.
Practical Implication
This example demonstrates that, where the residence and tax liability requirements for the last three calendar years are satisfied simultaneously, the taxpayer may benefit from the exemption.
Example 2 – Failure to Apply Within the Prescribed Period
In the second example, (B), who became resident in Türkiye on 2 March 2028, applied for an exemption certificate on 1 May 2030.
Although the taxpayer had neither a residence nor an income tax liability in Türkiye in 2025, 2026 and 2027, the Communiqué provides that an Exemption Certificate would not be issued because the application was not submitted within the prescribed period.
Practical Implication
This example demonstrates that satisfying the substantive conditions alone is not sufficient; compliance with the prescribed application periods is also mandatory.
Example 3 – Commencement of a Commercial Activity in Türkiye
In the third example, (C), who became resident in Türkiye on 12 May 2028, commenced a retail business involving the sale of ready-made clothing products on 30 October 2028 and subsequently applied for an exemption certificate on 15 November 2028.
The Communiqué states that, provided it is determined that the taxpayer had neither a residence nor an income tax liability in Türkiye during 2025, 2026 and 2027, commencing a commercial activity in Türkiye does not prevent the issuance of an exemption certificate.
Practical Implication
Commencing a commercial activity after becoming resident in Türkiye does not, by itself, prevent the taxpayer from benefiting from the exemption. The key consideration is whether the relevant conditions for the last three calendar years prior to becoming resident in Türkiye have been satisfied.
Example 4 – Being Resident in Türkiye During One of the Last Three Calendar Years
The fourth example concerns (D), who had a residence in Türkiye in 2022, left Türkiye on 10 November 2024 and returned to Türkiye in 2027.
The Communiqué provides that, since the taxpayer was resident in Türkiye during the 2024 calendar year, the three-calendar-year requirement was not satisfied and therefore an Exemption Certificate could not be issued.
Practical Implication
Having a residence or an income tax liability in Türkiye during any of the last three calendar years constitutes an obstacle to benefiting from the exemption.
Specific Situations Regarding Obtaining an Exemption Certificate
General Communiqué No. 333 also addresses certain specific situations that may give rise to questions regarding the issuance of an exemption certificate.
In particular, the Communiqué explains through examples the impact of having a tax liability arising from certain types of income before becoming resident in Türkiye, as well as the consequences of having an income tax liability arising from employment income or commercial income in Türkiye.
Example 5 – Having an Income Tax Liability Due to Rental Income
In the fifth example provided in the Communiqué, (E), who became resident in Türkiye on 12 May 2028, had been earning rental income in Türkiye since 7 May 2026 and filing a tax return in respect of such income.
The Communiqué states that, provided that the taxpayer applies for an exemption certificate by the end of the 2028 calendar year and satisfies the other applicable conditions, the existence of an income tax liability solely due to rental income does not prevent the issuance of an Exemption Certificate.
Practical Implication
This example demonstrates that having an income tax liability in Türkiye solely due to rental income before becoming resident in Türkiye does not, provided that the other conditions under the Communiqué are satisfied, prevent the issuance of an Exemption Certificate. Accordingly, such tax liability alone does not eliminate the right to benefit from the exemption.
Example 6 – Having an Income Tax Liability Due to Employment Income
In the sixth example, (F), who became resident in Türkiye on 23 July 2028, is stated to have earned employment income subject to withholding tax from a single employer during the last three calendar years prior to becoming resident in Türkiye.
The Communiqué explains that, because the taxpayer had an income tax liability arising from such employment income, an Exemption Certificate could not be issued even if the other conditions were satisfied.
Practical Implication
Employment income earned before becoming resident in Türkiye prevents the taxpayer from satisfying the requirement under the Communiqué concerning the absence of an income tax liability in Türkiye and therefore constitutes an obstacle to benefiting from the exemption.
Example 7 – Having an Income Tax Liability Due to Commercial Income
In the seventh example, (G), who became resident in Türkiye on 15 September 2028, had an income tax liability in Türkiye arising from commercial income as of 1 January 2026.
Although the taxpayer applied for an exemption certificate within the period prescribed under the Communiqué, it is stated that an Exemption Certificate could not be issued because the taxpayer had an income tax liability arising from commercial income during the 2026 calendar year.
Practical Implication
Where an income tax liability exists before becoming resident in Türkiye due to:
BeOne Assessment
When the examples provided in the Communiqué are evaluated together, it is understood that the nature of the income tax liability during the last three calendar years prior to becoming resident in Türkiye is a determining factor in the issuance of an exemption certificate.
In particular:
Which Types of Income Fall Within the Scope of the Exemption?
Pursuant to General Communiqué No. 333, the exemption applies only to income and gains derived outside Türkiye.
On the other hand, taxpayers benefiting from the exemption remain subject to their existing tax obligations with respect to income and gains derived in Türkiye. Accordingly, holding an Exemption Certificate does not mean that the taxpayer's Türkiye-source income is also exempt from taxation.
The Communiqué explains this distinction through various examples.
Example 8 – Rental Income Derived from Real Estate Located Abroad
In the eighth example provided in the Communiqué, (H), who benefits from the exemption:
The Communiqué further clarifies that rental income falling within the scope of the exemption is not required to be included in the annual income tax return; even where the taxpayer is required to file a tax return due to other income, such exempt income is not included in the return.
Practical Implication
Rental income derived from real estate located abroad may benefit from the income tax exemption, provided that the other applicable conditions are satisfied.
Example 9 – Rental Income Derived from Real Estate Located in Türkiye
In the ninth example, (I), who benefits from the exemption, earns rental income from real estate located in Türkiye.
According to the Communiqué, since such rental income is derived in Türkiye, it does not fall within the scope of the exemption and remains subject to taxation under the general provisions.
Practical Implication
The exemption applies only to foreign-source income. Rental income derived from real estate located in Türkiye cannot benefit from the exemption.
Example 10 – Consultancy Services Performed in Türkiye
In the tenth example, (J), who benefits from the exemption, operates as an engineer in Türkiye and provides consultancy services to customers resident abroad in relation to their investments in Türkiye.
The Communiqué states that the fact that the recipients of the services are located abroad does not change the outcome. Since the services are performed in Türkiye, the resulting self-employment income does not fall within the scope of the exemption.
Practical Implication
When determining the source of income, the location of the customer is not the determining factor; rather, the place where the activity is performed is relevant. Income derived from services performed in Türkiye cannot benefit from the exemption.
Example 11 – Earning Income Both in Türkiye and Abroad
In the eleventh example provided in the Communiqué, (K), who benefits from the exemption, earns:
Practical Implication
A taxpayer may simultaneously earn income both in Türkiye and abroad. In such cases, each income item should be evaluated separately based on its source, and only income and gains derived abroad should be considered within the scope of the exemption.
BeOne Assessment
The examples provided in the Communiqué clearly demonstrate that the place where the income is derived is a determining factor in applying the exemption.
Accordingly:
On the other hand:
Therefore, taxpayers benefiting from the exemption should properly classify their income according to its source and apply the exemption only to foreign-source income that falls within the scope of the Communiqué.
Taxpayers Subsequently Determined Not to Satisfy the Exemption Conditions
General Communiqué No. 333 also sets out the tax consequences applicable where a taxpayer is subsequently determined to have benefited from the exemption despite not satisfying the relevant exemption conditions.
Accordingly, where a taxpayer is determined to have benefited from the exemption despite not satisfying the applicable conditions, the under-assessed taxes relating to the income and gains treated as exempt will be assessed by the competent tax office together with a tax loss penalty and late payment interest.
Example Provided in the Communiqué
Example 12 – Subsequent Determination That the Exemption Conditions Were Not Satisfied
In the example provided in the Communiqué, taxpayer (L), who became resident in Türkiye on 12 May 2026, applied for an exemption certificate on 1 December 2026.
The Communiqué explains that, where an examination subsequently determines that the taxpayer benefited from the exemption despite not satisfying the exemption conditions, the under-assessed taxes will be collected together with a tax loss penalty and late payment interest.
Practical Implication
Obtaining an Exemption Certificate alone is not sufficient. If it is subsequently determined that the exemption conditions were not satisfied, the tax benefit obtained will be recovered together with the applicable penalties and interest.
Status of Individuals Who Are Not Considered Resident in Türkiye
The Communiqué also provides explanations regarding the taxation of income derived abroad by individuals who are not considered resident in Türkiye.
Accordingly, for individuals who are not considered resident in Türkiye, only income and gains derived in Türkiye are subject to taxation in Türkiye, whereas income and gains derived outside Türkiye are not subject to taxation in Türkiye.
Example Provided in the Communiqué
Example 13 – Foreign-Source Income of an Individual Not Resident in
Türkiye
In the example provided in the Communiqué, (M), who has a residence in the United Arab Emirates and is not considered resident in Türkiye:
Practical Implication
For individuals who are not considered resident in Türkiye, the determining factor for taxation is not the transfer of income to Türkiye, but rather where the income is derived and the individual's tax residency status.
General Communiqué No. 333 on Income Tax sets out the procedures and principles for the implementation of Repetitive Article 20/D of the Income Tax Code, introduced by Article 4 of Law No. 7582.
Under the relevant provision:
- Certain individuals who become resident in Türkiye
- Income and gains derived outside Türkiye by such individuals
- Provided that the prescribed conditions are satisfied
- Are exempt from income tax for a period of 20 years
What Is the Purpose of the Regulation?
The main purpose of the regulation is to encourage individuals residing abroad who plan to relocate to Türkiye to return to Türkiye and to increase Türkiye's attractiveness for qualified human resources and capital by reducing the tax burden on their foreign-source income.
Within this framework, income and gains derived abroad by individuals satisfying the relevant conditions are exempt from income tax for 20 years, notwithstanding that such individuals are considered fully liable taxpayers in Türkiye.
However, the Communiqué makes it clear that the exemption does not apply automatically. In order to benefit from the exemption, all conditions prescribed under the Communiqué must be satisfied and an Exemption Certificate must be obtained.
Who May Benefit from the Exemption?
Pursuant to General Communiqué No. 333 on Income Tax, the income tax exemption is available only to individuals. Corporate income taxpayers cannot benefit from this exemption.
The following conditions must be satisfied simultaneously in order to benefit from the exemption:
- Being an individual considered to be resident in Türkiye as of the application date
- Not having had a residence in Türkiye during the last three calendar years prior to becoming resident in Türkiye
- Not having been an income taxpayer in Türkiye during the same three-calendar-year period
- Having become resident in Türkiye as of 1 January 2026; and
- Obtaining an Exemption Certificate within the period prescribed under the Communiqué
Examples Provided in the Communiqué
Example 1 – Issuance of an Exemption Certificate Where the Conditions Are Satisfied
In the first example provided in the Communiqué, (A), who became resident in Türkiye on 12 July 2026, applied to the tax office on 1 December 2026 to obtain an exemption certificate.
As a result of the examination conducted by the tax office, it was determined that the taxpayer had neither a residence nor an income tax liability in Türkiye during the 2023, 2024 and 2025 calendar years. Accordingly, the taxpayer would be issued an Exemption Certificate.
Practical Implication
This example demonstrates that, where the residence and tax liability requirements for the last three calendar years are satisfied simultaneously, the taxpayer may benefit from the exemption.
Example 2 – Failure to Apply Within the Prescribed Period
In the second example, (B), who became resident in Türkiye on 2 March 2028, applied for an exemption certificate on 1 May 2030.
Although the taxpayer had neither a residence nor an income tax liability in Türkiye in 2025, 2026 and 2027, the Communiqué provides that an Exemption Certificate would not be issued because the application was not submitted within the prescribed period.
Practical Implication
This example demonstrates that satisfying the substantive conditions alone is not sufficient; compliance with the prescribed application periods is also mandatory.
Example 3 – Commencement of a Commercial Activity in Türkiye
In the third example, (C), who became resident in Türkiye on 12 May 2028, commenced a retail business involving the sale of ready-made clothing products on 30 October 2028 and subsequently applied for an exemption certificate on 15 November 2028.
The Communiqué states that, provided it is determined that the taxpayer had neither a residence nor an income tax liability in Türkiye during 2025, 2026 and 2027, commencing a commercial activity in Türkiye does not prevent the issuance of an exemption certificate.
Practical Implication
Commencing a commercial activity after becoming resident in Türkiye does not, by itself, prevent the taxpayer from benefiting from the exemption. The key consideration is whether the relevant conditions for the last three calendar years prior to becoming resident in Türkiye have been satisfied.
Example 4 – Being Resident in Türkiye During One of the Last Three Calendar Years
The fourth example concerns (D), who had a residence in Türkiye in 2022, left Türkiye on 10 November 2024 and returned to Türkiye in 2027.
The Communiqué provides that, since the taxpayer was resident in Türkiye during the 2024 calendar year, the three-calendar-year requirement was not satisfied and therefore an Exemption Certificate could not be issued.
Practical Implication
Having a residence or an income tax liability in Türkiye during any of the last three calendar years constitutes an obstacle to benefiting from the exemption.
Specific Situations Regarding Obtaining an Exemption Certificate
General Communiqué No. 333 also addresses certain specific situations that may give rise to questions regarding the issuance of an exemption certificate.
In particular, the Communiqué explains through examples the impact of having a tax liability arising from certain types of income before becoming resident in Türkiye, as well as the consequences of having an income tax liability arising from employment income or commercial income in Türkiye.
Example 5 – Having an Income Tax Liability Due to Rental Income
In the fifth example provided in the Communiqué, (E), who became resident in Türkiye on 12 May 2028, had been earning rental income in Türkiye since 7 May 2026 and filing a tax return in respect of such income.
The Communiqué states that, provided that the taxpayer applies for an exemption certificate by the end of the 2028 calendar year and satisfies the other applicable conditions, the existence of an income tax liability solely due to rental income does not prevent the issuance of an Exemption Certificate.
Practical Implication
This example demonstrates that having an income tax liability in Türkiye solely due to rental income before becoming resident in Türkiye does not, provided that the other conditions under the Communiqué are satisfied, prevent the issuance of an Exemption Certificate. Accordingly, such tax liability alone does not eliminate the right to benefit from the exemption.
Example 6 – Having an Income Tax Liability Due to Employment Income
In the sixth example, (F), who became resident in Türkiye on 23 July 2028, is stated to have earned employment income subject to withholding tax from a single employer during the last three calendar years prior to becoming resident in Türkiye.
The Communiqué explains that, because the taxpayer had an income tax liability arising from such employment income, an Exemption Certificate could not be issued even if the other conditions were satisfied.
Practical Implication
Employment income earned before becoming resident in Türkiye prevents the taxpayer from satisfying the requirement under the Communiqué concerning the absence of an income tax liability in Türkiye and therefore constitutes an obstacle to benefiting from the exemption.
Example 7 – Having an Income Tax Liability Due to Commercial Income
In the seventh example, (G), who became resident in Türkiye on 15 September 2028, had an income tax liability in Türkiye arising from commercial income as of 1 January 2026.
Although the taxpayer applied for an exemption certificate within the period prescribed under the Communiqué, it is stated that an Exemption Certificate could not be issued because the taxpayer had an income tax liability arising from commercial income during the 2026 calendar year.
Practical Implication
Where an income tax liability exists before becoming resident in Türkiye due to:
- Commercial income
- Self-employment income, or
- Employment income
BeOne Assessment
When the examples provided in the Communiqué are evaluated together, it is understood that the nature of the income tax liability during the last three calendar years prior to becoming resident in Türkiye is a determining factor in the issuance of an exemption certificate.
In particular:
- Having a tax liability solely due to rental income, investment income or capital gains does not constitute an obstacle to the exemption; whereas
- Having a tax liability arising from employment income, commercial income or self-employment income prevents the taxpayer from benefiting from the exemption
Which Types of Income Fall Within the Scope of the Exemption?
Pursuant to General Communiqué No. 333, the exemption applies only to income and gains derived outside Türkiye.
On the other hand, taxpayers benefiting from the exemption remain subject to their existing tax obligations with respect to income and gains derived in Türkiye. Accordingly, holding an Exemption Certificate does not mean that the taxpayer's Türkiye-source income is also exempt from taxation.
The Communiqué explains this distinction through various examples.
Example 8 – Rental Income Derived from Real Estate Located Abroad
In the eighth example provided in the Communiqué, (H), who benefits from the exemption:
- Earns rental income in Türkiye
- Earns investment income in Türkiye, and
- Also earns rental income from real estate located abroad
The Communiqué further clarifies that rental income falling within the scope of the exemption is not required to be included in the annual income tax return; even where the taxpayer is required to file a tax return due to other income, such exempt income is not included in the return.
Practical Implication
Rental income derived from real estate located abroad may benefit from the income tax exemption, provided that the other applicable conditions are satisfied.
Example 9 – Rental Income Derived from Real Estate Located in Türkiye
In the ninth example, (I), who benefits from the exemption, earns rental income from real estate located in Türkiye.
According to the Communiqué, since such rental income is derived in Türkiye, it does not fall within the scope of the exemption and remains subject to taxation under the general provisions.
Practical Implication
The exemption applies only to foreign-source income. Rental income derived from real estate located in Türkiye cannot benefit from the exemption.
Example 10 – Consultancy Services Performed in Türkiye
In the tenth example, (J), who benefits from the exemption, operates as an engineer in Türkiye and provides consultancy services to customers resident abroad in relation to their investments in Türkiye.
The Communiqué states that the fact that the recipients of the services are located abroad does not change the outcome. Since the services are performed in Türkiye, the resulting self-employment income does not fall within the scope of the exemption.
Practical Implication
When determining the source of income, the location of the customer is not the determining factor; rather, the place where the activity is performed is relevant. Income derived from services performed in Türkiye cannot benefit from the exemption.
Example 11 – Earning Income Both in Türkiye and Abroad
In the eleventh example provided in the Communiqué, (K), who benefits from the exemption, earns:
- Rental income from real estate located in Istanbul
- Dividends from a fully liable Turkish corporate taxpayer
- Dividend income from a company resident in Spain; and
- Rental income from real estate located in Monaco
- The rental income derived in Türkiye and the dividends received from the fully liable Turkish corporate taxpayer do not fall within the scope of the exemption; whereas
- The dividend income received from Spain and the rental income derived from real estate located in Monaco do fall within the scope of the exemption
Practical Implication
A taxpayer may simultaneously earn income both in Türkiye and abroad. In such cases, each income item should be evaluated separately based on its source, and only income and gains derived abroad should be considered within the scope of the exemption.
BeOne Assessment
The examples provided in the Communiqué clearly demonstrate that the place where the income is derived is a determining factor in applying the exemption.
Accordingly:
- Rental income derived from real estate located abroad
- Dividends received from companies located abroad, and
- Other foreign-source income and gains, provided that the relevant conditions are satisfied
On the other hand:
- Rental income derived from real estate located in Türkiye
- Income derived from self-employment activities performed in Türkiye, and
- Other Türkiye-source income
Therefore, taxpayers benefiting from the exemption should properly classify their income according to its source and apply the exemption only to foreign-source income that falls within the scope of the Communiqué.
Taxpayers Subsequently Determined Not to Satisfy the Exemption Conditions
General Communiqué No. 333 also sets out the tax consequences applicable where a taxpayer is subsequently determined to have benefited from the exemption despite not satisfying the relevant exemption conditions.
Accordingly, where a taxpayer is determined to have benefited from the exemption despite not satisfying the applicable conditions, the under-assessed taxes relating to the income and gains treated as exempt will be assessed by the competent tax office together with a tax loss penalty and late payment interest.
Example Provided in the Communiqué
Example 12 – Subsequent Determination That the Exemption Conditions Were Not Satisfied
In the example provided in the Communiqué, taxpayer (L), who became resident in Türkiye on 12 May 2026, applied for an exemption certificate on 1 December 2026.
The Communiqué explains that, where an examination subsequently determines that the taxpayer benefited from the exemption despite not satisfying the exemption conditions, the under-assessed taxes will be collected together with a tax loss penalty and late payment interest.
Practical Implication
Obtaining an Exemption Certificate alone is not sufficient. If it is subsequently determined that the exemption conditions were not satisfied, the tax benefit obtained will be recovered together with the applicable penalties and interest.
Status of Individuals Who Are Not Considered Resident in Türkiye
The Communiqué also provides explanations regarding the taxation of income derived abroad by individuals who are not considered resident in Türkiye.
Accordingly, for individuals who are not considered resident in Türkiye, only income and gains derived in Türkiye are subject to taxation in Türkiye, whereas income and gains derived outside Türkiye are not subject to taxation in Türkiye.
Example Provided in the Communiqué
Example 13 – Foreign-Source Income of an Individual Not Resident in
Türkiye
In the example provided in the Communiqué, (M), who has a residence in the United Arab Emirates and is not considered resident in Türkiye:
- Transfers USD 100,000 from abroad to a bank account held in Türkiye; and
- Also transfers EUR 50,000 of rental income derived from real estate
- Located in France to the same account
Practical Implication
For individuals who are not considered resident in Türkiye, the determining factor for taxation is not the transfer of income to Türkiye, but rather where the income is derived and the individual's tax residency status.
CONCLUSION
General Communiqué No. 333 on Income Tax sets out the procedures and principles for the implementation of the 20-year income tax exemption introduced under Repetitive Article 20/D of the Income Tax Code within the scope of Law No. 7582.
The Communiqué clarifies the persons eligible for the exemption, the application process, the issuance of the exemption certificate and the types of income falling within the scope of the exemption, while also addressing potential practical uncertainties through detailed examples.
When the examples provided in the Communiqué are evaluated together, it is understood that merely becoming resident in Türkiye is not sufficient to benefit from the exemption. Compliance with the conditions relating to the last three calendar years, obtaining the Exemption Certificate within the prescribed period and correctly determining the source of income are of particular importance.
Accordingly, individuals planning to relocate to Türkiye should carefully assess their tax position before applying for the exemption, properly classify income falling within the scope of the exemption and timely fulfil the application and documentation requirements prescribed under the Communiqué.
General Communiqué No. 333 on Income Tax sets out the procedures and principles for the implementation of the 20-year income tax exemption introduced under Repetitive Article 20/D of the Income Tax Code within the scope of Law No. 7582.
The Communiqué clarifies the persons eligible for the exemption, the application process, the issuance of the exemption certificate and the types of income falling within the scope of the exemption, while also addressing potential practical uncertainties through detailed examples.
When the examples provided in the Communiqué are evaluated together, it is understood that merely becoming resident in Türkiye is not sufficient to benefit from the exemption. Compliance with the conditions relating to the last three calendar years, obtaining the Exemption Certificate within the prescribed period and correctly determining the source of income are of particular importance.
Accordingly, individuals planning to relocate to Türkiye should carefully assess their tax position before applying for the exemption, properly classify income falling within the scope of the exemption and timely fulfil the application and documentation requirements prescribed under the Communiqué.
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