Tax residency for foreigners in Turkey is decided by the Income Tax Law (Gelir Vergisi Kanunu), not by the residence permit: a person is a full taxpayer, taxed on worldwide income, if their domicile is in Turkey or if they stay in Turkey for more than six months in a calendar year, and everyone else is a limited taxpayer, taxed only on income sourced in Turkey. This article explains the two tests and the exception for temporary stays, what the status changes in practice, the exemption introduced in 2026 for the foreign income of people who newly settle in Turkey, how double taxation treaties, the certificate of residence and the foreign tax credit work, how employment, remote work and self-employment are taxed, what property owners declare, and how registration, filing, audits and disputes run before the Revenue Administration (Gelir İdaresi Başkanlığı).
- Two independent tests: domicile in Turkey, or more than six months in Turkey in a calendar year; temporary absences do not interrupt the count.
- Foreigners in Turkey for a defined temporary purpose, such as study, treatment or a specific assignment, are not treated as settled even beyond six months.
- Full taxpayers declare worldwide income; limited taxpayers declare Turkish-source income only.
- Since 2026, people who become resident after three years without Turkish residence or tax liability can obtain a twenty-year exemption for income earned abroad, on application.
- Treaty tie-breakers, the certificate of residence and the foreign tax credit decide what double taxation remains.
Who is a full taxpayer: domicile, the six-month test and the temporary-stay exception
The Income Tax Law treats as settled in Turkey, and therefore as a full taxpayer (tam mükellef), two groups of people. The first are those whose domicile (ikametgâh) is in Turkey, taking the Civil Code's (Türk Medeni Kanunu) meaning of the place where a person lives with the intention of staying; the second are those who stay in Turkey for more than six months in a single calendar year, with temporary departures not interrupting the stay. The two tests are alternatives: a foreign national who owns a home in Istanbul, holds a residence permit, has registered an address and lives there with their family is domiciled in Turkey whatever their day count, and a foreign national who keeps their home abroad but spends seven months of the year in Turkey is settled by the second test whatever their intention.
The Law makes an exception for foreigners who are in Turkey for a defined and temporary purpose: scientists, experts and officials on a specific assignment, press correspondents, and people who come for study, medical treatment, rest or travel are not treated as settled even if their stay exceeds six months, as are people held in Turkey against their will, for example by detention or illness. The exception turns on the purpose and the temporary character of the stay, and it is the provision on which an international assignee with a fixed-term posting relies; it does not help a person who has moved their life to Turkey and describes the move as temporary. In our practice the Revenue Administration looks at the pattern, not the label: the permit type, the lease, the family's whereabouts, the children's school and the bank accounts.
Two further points are often missed. Residency is assessed by calendar year, so a person can be a limited taxpayer one year and a full taxpayer the next, and the arrival and departure years need their own analysis of which income falls into the Turkish net. And the six-month test is a domestic rule counted in months of stay, not the 183-day formula that appears in treaties for employment income; the two are related but not the same, and the Revenue Administration reads entry and exit records from the Migration Management when it counts. A residence permit neither creates nor prevents tax residency by itself, but a long-term permit, an address registration and a Turkish identity number are the documents the tax office reads first. Our note on expat taxation in Turkey covers the filing side for foreign residents in more detail.
What the status changes: worldwide income, Turkish-source income and the source rules
A full taxpayer declares in Turkey all income earned anywhere: salary, business and professional income, rental income from property in Turkey or abroad, dividends, interest and capital gains, and foreign pensions, each under its own rules and exemptions, with relief for foreign tax under a treaty or the domestic credit described below. A limited taxpayer (dar mükellef) declares only income the Law treats as earned in Turkey, and much of that income is taxed by withholding at source without a return, so that a non-resident who receives a Turkish salary through a Turkish payroll, or interest from a Turkish bank, may have no filing to make at all.
The source rules decide what a non-resident owes. Employment income is Turkish-source where the work is performed in Turkey or the salary is paid or accounted for in Turkey; professional and business income where the activity is carried on in Turkey or the payment is made or booked there; rental income where the property is in Turkey; capital gains where the asset or the transaction is in Turkey; dividends and interest where the paying company or debtor is in Turkey. The rule that catches people is the one on where the work is done: a consultant who sits in Istanbul and invoices clients in London is earning Turkish-source income even as a non-resident, because the service is performed in Turkey.
Foreign nationals who come to Turkey on secondment often fall within a specific exemption for wages paid in foreign currency by an employer established abroad out of its foreign earnings to staff working in Turkey, commonly used for liaison offices, and the conditions of that exemption, including that the salary is not charged to a Turkish entity, are checked before relying on it. Our practice page on tax law in Turkey sets out the income categories and rates framework; this article stays on the residency question.
The 2026 exemption for foreign income of people who newly settle in Turkey
An amendment to the Income Tax Law enacted in May 2026, with a General Communiqué of the Revenue Administration published in July 2026, introduced an exemption for earnings and income obtained outside Turkey by individuals who become settled in Turkey from the start of 2026 onward. The core condition is that in the three calendar years before becoming resident the person had neither a domicile in Turkey nor a Turkish tax liability, with an earlier liability arising only from Turkish rental income, securities income or capital gains not counting against them. The exemption runs for twenty years and covers income from abroad only; Turkish-source income remains taxable under the ordinary rules.
The exemption is not automatic. The person applies to the competent tax office and obtains an exemption certificate for income from abroad (istisna belgesi), ordinarily by the end of the calendar year in which they become resident, with a short extension into the following year for those who become resident in November or December; a person who is deemed resident in August applies by the end of that December. Exempt income is left out of any annual return, expenses related to it cannot be deducted, and foreign tax paid on it cannot be credited against Turkish tax. If a condition is later found not to have been met, the tax not assessed is treated as lost, with the penalties that follow.
For a foreign retiree, investor or remote worker moving to Turkey, this provision changes the planning: the question is no longer only whether they will become a full taxpayer, but whether they qualify for the exemption and how to document the three clean years and the date of settlement. In our practice the application is prepared with the residence permit file, the lease or title deed, the entry and exit records and, where the person previously held a Turkish address registration, evidence of residence abroad during that period, because the Revenue Administration's early rulings turn on exactly that documentation. The provision is new and its administration is still settling; a decision to rely on it is taken on the current text and the current rulings. Practice may vary by authority and year.
Treaties: the tie-breaker, the certificate of residence and the foreign tax credit
Turkey has double taxation treaties with a large number of countries, and a treaty matters in two situations: when both Turkey and the other state treat the person as resident under their own laws, and when a resident of one state earns income in the other. In the first case the treaty's tie-breaker assigns a single residence, usually in the order the OECD model uses: the state where the person has a permanent home available; if a home is available in both, the state with which their personal and economic relations are closer, the centre of vital interests; if that cannot be determined, the state where they habitually stay; then nationality; and finally agreement between the two tax authorities. Each step is applied only if the previous one does not settle the question, and the facts that decide it are the same facts the domestic tests look at: where the family lives, where the work is, where the assets and the bank accounts are.
The certificate of residence (mukimlik belgesi) is the document that carries a treaty claim. A foreign national resident in Turkey who receives income from a treaty country obtains the certificate from the Revenue Administration, through the digital tax office or the tax office, to claim the treaty's reduced withholding abroad; a person resident abroad who receives Turkish income obtains the certificate from their home tax authority and presents it in Turkey, legalised and translated, to the payer or the tax office, under the Revenue Administration's communiqués on treaty relief. The certificate is issued for a tax year and states the status under a named treaty; a certificate from abroad does not override the Turkish facts, and a person who is settled in Turkey under the domestic tests but holds a foreign certificate must still win the tie-breaker on the facts.
Where no treaty applies, or where the treaty leaves income taxable in both states, the Income Tax Law allows a full taxpayer to credit income tax paid abroad on foreign income against the Turkish tax on that same income, up to the Turkish tax attributable to it, on proof of payment certified by the Turkish consulate or otherwise in the form the Revenue Administration accepts. The credit, the treaty and the 2026 exemption are alternatives for the same income, and the choice is made per income category each year.
Employment, assignments, remote work and self-employment
For an employee on a Turkish payroll, the employer withholds income tax on the salary at the progressive rates and the employee ordinarily files no return for that salary alone; a resident with more than one employer, or with salary above the threshold the Law sets, files an annual return. A foreign national posted to Turkey by a foreign employer presents three questions: whether the person becomes a full taxpayer under the six-month test or stays within the temporary-assignment exception; whether the salary is Turkish-source because the work is performed in Turkey, which it usually is; and whether a treaty's employment article leaves the right to tax with the home state for a short stay, typically where the person is present for no more than 183 days in the relevant period, the employer is not resident in Turkey and the cost is not borne by a Turkish permanent establishment. Where the salary is paid abroad and nothing is withheld in Turkey, the employee declares the Turkish-source salary in an annual return, a step that foreign assignees often learn of from an audit rather than from their employer.
An employee's presence can also create a problem for the employer: a person who habitually concludes contracts in Turkey for a foreign company, or who works from a fixed place in Turkey that the company uses, can constitute a permanent establishment of that company under the Corporate Tax Law (Kurumlar Vergisi Kanunu) and the treaty, bringing part of the company's profit into Turkish corporate tax. Assignments are structured with that risk in view, and where a Turkish company is the right answer, the founder's own tax position follows; our note on company formation and residence permits for foreign founders covers that route.
Self-employed professionals and remote workers are taxed on the place of performance. A foreign national who provides services from Turkey, to Turkish or foreign clients, earns professional income sourced in Turkey; as a full taxpayer they register with the tax office, keep the books the Tax Procedure Law (Vergi Usul Kanunu) requires, issue invoices, charge value added tax where the service is not exported, and file an annual return; as a limited taxpayer they still owe Turkish tax on the Turkish-source portion. Registration as self-employed also brings compulsory social insurance in the self-employed category unless a social security agreement keeps the person in their home scheme. The 2026 exemption does not cover this income, because it is earned in Turkey. Our practice page on the tax lawyer in Turkey covers structuring for professionals and founders.
Property owners: rental income and capital gains for residents and non-residents
Rental income from property in Turkey is Turkish-source for everyone. A full taxpayer declares it in the annual return with their other income; a limited taxpayer declares it in an annual return limited to that income, filed and paid in the same March window. Residential rent benefits from an annual exemption set each year, and expenses are deducted either as actually incurred and documented or as a lump-sum percentage of the gross rent, an election that binds for a period once made; rent must be collected through a bank or the postal service, and cash collection is penalised. Income from furnished short-term letting is treated and licensed differently, and a foreign owner who lets through a platform is within the Revenue Administration's data-matching.
Capital gains on the sale of real estate acquired for consideration are taxable when the property is sold within five years of acquisition, with the acquisition cost indexed for inflation and an annual exemption applied; a sale after five years, or of property acquired by inheritance or gift, is outside the charge. The rule applies to residents and non-residents alike, because the gain is Turkish-source, and a treaty ordinarily leaves the right to tax immovable property with the state where it is situated. The purchase price recorded at the Land Registry, the notary and bank records of the payment, and the invoices for improvements are the documents that fix the gain, and a buyer who under-declared the price at purchase pays for it at the sale.
Owning property is also a residency fact. A home kept available in Turkey, used on every visit, with utilities and a registered address, weighs in the domicile test and in a treaty's permanent-home test, and a foreign owner who wants to remain a non-resident keeps the pattern of use consistent with that aim. In our files the owner who rents the property out on a long lease, keeps no registered address at it and stays elsewhere when visiting is in a different position from the owner who keeps the keys. Practice may vary by authority and year.
Registration, filing, audits and remedies
A foreign national deals with the tax office through a tax identification number, which the Revenue Administration issues to foreigners on application with a passport, including online through the interactive tax office, and which later merges with the foreigner identity number once a residence permit is issued. Returns are filed electronically through the digital tax office; the annual income tax return for the previous calendar year is filed in March and the tax paid in two instalments, in March and July, with the Revenue Administration's pre-filled return available for rental, salary and investment income. A person who becomes a full taxpayer registers at the tax office of their residence; a non-resident with Turkish income registers where the income arises or through a representative.
The Revenue Administration identifies foreigners with undeclared residency or income by matching data it already holds: entry and exit records, residence permits, address registrations, bank account openings and transfers, title deeds, rental contracts registered by notaries and platforms, and payroll declarations. An assessment reaches back within the statute of limitations, which runs five years from the start of the year following the tax year, with the tax, late-payment interest and a tax-loss penalty; a person who comes forward before an audit under the voluntary disclosure procedure of the Tax Procedure Law pays the tax and interest and avoids the penalty, which is the usual route for a foreign resident who discovers an unfiled year.
A disputed assessment is challenged by a request for settlement (uzlaşma) with the administration, by a reduction in penalties on acceptance, or by an action before the tax court within thirty days of the notice, which suspends collection while the case is pending at first instance; the decision is appealed to the Regional Administrative Court and, above a threshold, to the Council of State. Our note on tax dispute resolution in Turkey covers those stages. A residency dispute is won on documents assembled before it starts: the entry and exit record, the lease or title, the employment or assignment contract, the family's residence and schooling, the foreign tax returns and certificates, and, where the 2026 exemption is claimed, the certificate and the evidence of the three prior years.
Frequently asked questions
- Does a Turkish residence permit make me a tax resident? Not by itself. Tax residency follows the Income Tax Law's tests, domicile in Turkey or more than six months in Turkey in a calendar year, but the permit, the address registration and the lease are the facts the tax office reads when it applies them.
- Is the rule 183 days? The domestic test is more than six months in a calendar year, temporary absences included; the 183-day figure comes from the employment article of most treaties, which decides which state taxes a short-term posting, not whether you are resident.
- I am in Turkey for a one-year assignment. Am I a full taxpayer? A foreigner present for a defined temporary purpose or assignment is not treated as settled even beyond six months, but the salary for work performed in Turkey is Turkish-source and taxable in Turkey unless a treaty's short-stay rule applies; the exception is lost once the move stops being temporary in fact.
- What is the 2026 exemption for income from abroad? Individuals who become settled in Turkey from 2026, after three calendar years with no Turkish domicile or tax liability, can obtain an exemption certificate from the tax office and keep income earned outside Turkey out of Turkish tax for twenty years; the application is due by the end of the year of settlement, and Turkish-source income stays taxable.
- What if both Turkey and my home country treat me as resident? The treaty tie-breaker decides, in order: permanent home, centre of vital interests, habitual abode, nationality, then agreement between the authorities. The facts are the same as in the domestic tests, so the file is prepared once.
- Do I pay Turkish tax on rent and sale gains from my Turkish flat if I live abroad? Yes. Rental income is declared annually in Turkey by non-residents too, and a gain on a sale within five years of acquisition is taxable with indexation and an exemption; after five years, or for inherited property, there is no charge.
- I have not filed for past years. What are my options? Voluntary disclosure under the Tax Procedure Law before an audit, paying the tax with interest and no penalty; otherwise an assessment within the five-year limitation, followed by settlement or a tax court action within thirty days of the notice.
Author: Av. Mirkan Günay Topcu, Managing Partner, ER&GUN&ER Law Firm, Istanbul Bar No. 67874. He advises foreign residents, assignees, remote workers and property owners on Turkish tax residency, treaty relief and the certificate of residence, the 2026 foreign-income exemption, registration and filing, and the defence of assessments before the Revenue Administration and the tax courts. Education: Istanbul University Faculty of Law (2018); Galatasaray University, LL.M. (2022).
Profile: Av. Mirkan Günay Topcu. LinkedIn: Profile. Istanbul Bar Association: Official website. Related practice page: residence permit in Turkey.